NewChannels Corp. v. Tax Appeals Tribunal of the Department of Taxation & Finance

OPINION OF THE COURT

Crew III, J.

The facts in this proceeding are largely undisputed. During the years in issue, 1989 through 1992, petitioners1 functioned as “cable operators.” In that capacity, petitioners collected television signals by various means (off-the-air broadcast, microwave and external satellite signals), clarified the signals, assigned them a channel frequency and transmitted the signals to subscribers through a system of coaxial cables and amplifiers. Petitioners had no control over the content of the signal received; all they could do was “get rid of the ghosts” and make the…