The opinion
Per Curiam.
The principal controversy between the parties is the inclusion by the commissioner of the cost -of' the license agreements in determining the value of appellant’s film library.
A case closely in point is Michael Todd Co. v. County of Los Angeles (1962), 57 Cal. 2d 684 , 371 P. 2d 340 , which concerned the valuation for property tax purposes of the *178 negatives to the movie “Around The World In Eighty Days.” The court stated at page 696:
“* * * But it does not follow * * * that as a matter of tax law the ‘market value’ of the negatives — which cost some $5,000,000 to produce and had a potential earning power of many millions of dollars — was simply their salvage or scrap value of $1,000. The record established, rather, that for the purpose of -determining, ‘full cash value’ there was no actual marhet for the negatives without plaintiff’s copyright therein. The sole beneficial or productive use of the negative film of a motion picture is for making prints thereof for exhibition, whether such prints be sold or leased. * * (Emphasis sic.)
For tax purposes, appellant Twyman Films did not report in its tax returns the value of the film library at its “book value.” Appellant in fact only reported a value calculated by its accountant on a basis unrelated to what appellant had paid for the right to use the copyrighted films in its business.
■This court does not find the decision of the board to be either unreasonable or unlawful, and it is therefore affirmed. •
Decision affirmed.
O’Neill, C. J., Herbert, Celebrezze, W. Brown, Cole, Cock and Locher, JJ., concur.
• Cole, J., of the.Third Appellate District, sitting for P. Brown, J.
Cook, J., of the Eleventh Appellate District, sitting for Sweeney, J.