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
PIEDRAS NEGRAS BROADCASTING CO., AND/OR CIA RADIO DIFUSORA DE PIEDRAS NEGRAS, S.A., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Piedras Negras Broadcasting Co. v. Commissioner
Docket No. 97045.
United States Board of Tax Appeals
43 B.T.A. 297; 1941 BTA LEXIS 1520;
January 14, 1941, Promulgated
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…
2Cases cited22 opinions
- M'culloch v. State of MarylandSupreme Court of the United States · 1819
- 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
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