In 1928, the Court went so far as to hold that a state could not tax as income royalties for the use of a patent issued by the United States.169 This proposition was soon overruled in Fox Film Corp. v. Doyal,170 where a privilege tax based on gross income and applicable to royalties from copyrights was upheld. Likewise a state may lay a franchise tax on corporations, measured by the net income from all sources and applicable to income from copyright royalties.171


Long v. Rockwood, 277 U.S. 142 (1928). [Back to text]
286 U.S. 123 (1932). [Back to text]
Educational Films Corp. v. Ward, 282 U.S. 379 (1931). [Back to text]