Legal Opinion

Wurlitzer Co. v. State Tax Commission

New York Court of Appeals

Decided July 11, 1974PublishedCited by 18 opinions

1Opinion of the Court

*103Stevens, J.

The Wurlitzer Company (Wurlitzer) is a foreign corporation doing business in New York. In 1957, it formed the Wurlitzer Acceptance Corporation (WAC), a foreign corporation not doing business in New York, whose sole purpose is to provide financing to Wurlitzer by purchasing Wurlitzer’s accounts receivable (security agreements), pursuant to a contract between them. Wurlitzer does all of the work of collecting the accounts and receives a fee therefor from WAC. At the time of the formation of WAC, Wurlitzer contributed capital of two and one-half million dollars in the form of accounts…

2Cases cited3 opinions

  1. Butler Bros. v. McColgan, Franchise Tax CommissionerSupreme Court of the United States · 1942
  2. Underwood Typewriter Co. v. ChamberlainSupreme Court of the United States · 1920
  3. People Ex Rel. Standard Oil Co. v. . LawNew York Court of Appeals · 1923

3Cited by18 opinions

  1. Coleco Industries, Inc. v. State Tax CommissionAppellate Division of the Supreme Court of the State of New York · 1983
  2. Matter of Standard Mfg. Co., Inc. v. Tax Comm'n of the State of New YorkNew York Court of Appeals · 1986
  3. Westinghouse Electric Corp. v. TullyNew York Court of Appeals · 1982
  4. Disney Enterprises, Inc. v. Tax Appeals TribunalAppellate Division of the Supreme Court of the State of New York · 2007
  5. Matter of Campbell Sales Co. v. New York State Tax Comm'nNew York Court of Appeals · 1986

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