Affiliated Enterprises, Inc. v. Commissioner
United States Board of Tax Appeals
1. Taxpayer was organized to carry on the business of selling a sales promotion or advertising plan, originated by its two chief stockholders, known as Bank Night, or the Affiliated System. The system was not patented or copyrighted, although some instruction sheets were copyrighted. Petitioner's income, in excess of 80 percent, was derived from payments from theatre operators under contracts designated as license agreements.
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1. Taxpayer was organized to carry on the business of selling a sales promotion or advertising plan, originated by its two chief stockholders, known as Bank Night, or the Affiliated System. The system was not patented or copyrighted, although some instruction sheets were copyrighted. Petitioner's income, in excess of 80 percent, was derived from payments from theatre operators under contracts designated as license agreements. Over 50 percent of petitioner's stock was held by less than 5 persons. Respondent determined that petitioner was subject to surtax as a personal holding company under…
1Opinion of the Court
AFFILIATED ENTERPRISES, INC., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Affiliated Enterprises, Inc. v. Commissioner
Docket No. 96603.
United States Board of Tax Appeals
42 B.T.A. 390; 1940 BTA LEXIS 1011;
July 19, 1940, Promulgated
1. Taxpayer was organized to carry on the business of selling a sales promotion or advertising plan, originated by its two chief stockholders, known as Bank Night, or the Affiliated System. The system was not patented or copyrighted, although some instruction sheets were copyrighted. Petitioner's income, in excess of 80 percent, was derived from…
2Cases cited1 opinion
- Affiliated Enterprises, Inc. v. CommissionerUnited States Board of Tax Appeals · 1940