Simplicity Pattern Co. V. State Board Of Equalization

Plaintiff Simplicity Pattern Company appeals from a judgment in favor of defendant Board of Equalization. The judgment denies a refund of sales tax on the transfer of film negatives and master recordings used to make audiovisual materials that help train nurses, paramedics, and other medical personnel. The transfer was part of a sale by plaintiff of the segment of its business devoted to producing and marketing such materials, consummated in 1971 through an exchange of the assets and name of its wholly owned subsidiary, Trainex Corporation, for common stock of (but less than a controlling interest in) Medcom, Inc., the transferee's parent. Trainex dissolved after the exchange, and plaintiff assumed its liabilities.