Summary
In Commonwealth v. Minnesota Mining and Manufacturing Company, 402 Pa. 612, 168 A.2d 560 (1961), we adopted the opinion of the lower court rejecting the taxpayer's claim that it was engaged in multiform business activities in which its income from royalties (from licensing of its patents) and technical fees was unrelated to its general mining and manufacturing business.
Summary of this case from Commonwealth v. ACF Industries, Inc.Opinion
January 10, 1961.
March 13, 1961.
Taxation — Foreign corporations — Corporate net income tax — Tax base — Income from royalties and technical fees — Multiform or unitary business.
Where the taxpayer, a foreign corporation, contended that in computing its corporate net income tax, income from royalties and technical fees should be excluded from the tax base upon the ground that it is engaged in a multiform business, but the court below concluded that the taxpayer's business is unitary in character and that the royalties and technical fees had been properly included in the tax base, it was Held that the judgment against the taxpayer should be affirmed.
Before JONES, C. J., BELL, MUSMANNO, JONES, COHEN, BOK and EAGEN, JJ.
Appeal, No. 52, May T., 1960, from judgment of Court of Common Pleas of Dauphin County, No. 193 Commonwealth Docket, 1954, in case of Commonwealth of Pennsylvania v. Minnesota Mining and Manufacturing Company. Judgment affirmed.
Same case in court below: 23 Pa. D. C.2d 337.
Proceedings on appeal from decision of Board of Finance and Revenue.
Opinion filed dismissing appeal, defendant's exceptions to opinion dismissed and judgment entered, opinion by RICHARDS, P. J. Defendant appealed.
John L. Connolly, with him William J. Begley, and Eastburn, Begley, Mandio, Kelton Popkin, for appellant.
Edward Friedman, Deputy Attorney General, with him Anne X. Alpern, Attorney General, for Commonwealth, appellee.
The judgment of the Court below is affirmed on the opinion of President Judge KARL E. RICHARDS.