Field Enterprises v. Department of Treasury

Defendant appeals as of right from an amended "consent” judgment entered in favor of plaintiff awarding it a tax refund, including penalties and interest. We reverse.

Plaintiff filed suit in the Court of Claims seeking a tax refund, arguing that defendant had improperly characterized payments plaintiff had made under a television syndication license agreement as royalties rather than rent. The parties agree that the television syndication license agreement which plaintiff entered into with Twentieth Century-Fox Television Corporation (Fox) on July 10, 1979, is representative of the agreements…