Piedras Negras Broadcasting Co. v. Commissioner
United States Board of Tax Appeals
A foreign corporation, having no office or place of business in the United States, which, pursuant to contracts executed at its foreign office, broadcasts from there programs designed in the main for listeners in the United States, for which it receives compensation or income in part in the United States from United States citizens in accordance with those contracts, held, not to receive compensation or income from sources within the United States and, therefore, not subject…
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A foreign corporation, having no office or place of business in the United States, which, pursuant to contracts executed at its foreign office, broadcasts from there programs designed in the main for listeners in the United States, for which it receives compensation or income in part in the United States from United States citizens in accordance with those contracts, held, not to receive compensation or income from sources within the United States and, therefore, not subject to income tax.
1Opinion of the Court
*303OPINION.
Disney:
The question presented for our consideration here is whether the petitioner, a foreign corporation organized and existing *304under the law of Mexico, received during the taxable years, 1936 and 1937, income from sources within the United States within the purview of section 231 (a), (b), and (d) of the Revenue Act of 1936.1
The facts involved here may be summarized as follows: Petitioner during 1936 and 1937 operated a broadcasting station which was located, both as to studio and transmitting station, in Mexico. It executed in Mexico contracts to broadcast advertising programs for…
2Cases cited16 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- Western Live Stock v. Bureau of RevenueSupreme Court of the United States · 1938
- International Textbook Co. v. PiggSupreme Court of the United States · 1910
- Fisher's Blend Station, Inc. v. State Tax CommissionSupreme Court of the United States · 1936
- People Ex Rel. Manila Electric Railroad & Lighting Corp. v. KnappNew York Court of Appeals · 1920
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3Cited by10 opinions
- Stemkowski v. CommissionerUnited States Tax Court · 1981
- Perkins v. CommissionerUnited States Tax Court · 1963
- Topps of Canada, Ltd. v. CommissionerUnited States Tax Court · 1961
- Container Corp. v. Comm'rUnited States Tax Court · 2010
- Container Corp. v. Comm'rUnited States Tax Court · 2010
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