SALSMAN, J.
Appellant Franchise Tax Board appeals from a judgment in favor of respondent RKO Teleradio Pictures, Inc., hereinafter referred to as RKO, directing a refund of taxes paid under protest for the income years 1945 and 1946.
The facts were stipulated. RKO's business is the production and distribution of motion pictures. It is a wholly owned subsidiary of Radio-Keith-Orpheum Corporation. Its principal offices are in New York City, where its managing...
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