Taxation — Foreign corporations — Corporate net income tax — Tax base — Income from royalties and technical fees — Multiform or unitary business.
Where the taxpayer, a foreign corporation, contended that in computing its corporate net income tax, income from royalties and technical fees should be excluded from the tax base upon the ground that it is engaged in a multiform business, but the court below concluded that the taxpayer's business is unitary in character and that the royalties and technical fees had been properly included in the tax base, it was Held that the judgment against the taxpayer should be affirmed.
OPINION PER CURIAM, March 13, 1961:
The judgment of the Court below is affirmed on the opinion of President Judge KARL E. RICHARDS.