Twentieth Century-Fox Film Corp. v. Lindley

The dispositive issue in this case is whether the income generated from the licensing of film prints by appellee '.can be characterized as net rents or royalties from tangible personal property, or as income from use of an intangible for the purposes of the Ohio franchise tax.

The assessment levied in this cause involves income which appellee receives from exhibitors and theater owners. Appellee’s motion picture productions result, in a master negative from which positive prints are produced. The positive prints, upon which appellee has obtained copyright protection, are then leased to…