Proposed Assessment of Additional Franchise Tax for the Taxable Quarters Ended March 31, 1980 v. Carolina Telephone & Telegraph Co.

EAGLES, Judge.

The sole question presented for review is whether the revenues received by Carolina from the sale of advertisements to appear in the “yellow page” classified directory are includable as “gross receipts” of a telephone company for franchise tax pur*242poses as defined in G.S. 105-120. We find that they are not and accordingly affirm.

G.S. 105420(b) imposes an annual franchise tax, payable quarterly, on the “gross receipts” of a telephone company. A telephone company is “[e]very person, firm, or corporation, domestic or foreign, owning and/or operating a telephone business for the…