Glatfelter Pulpwood Co. v. Commonwealth

OPINION

Justice McCAFFERY.

In this direct appeal, Glatfelter Pulpwood Company (“Appellant”) challenges the Commonwealth Court’s affirmance of the Board of Finance and Revenue’s determination that Appellant’s gains from the sale of a tract of Delaware timberland be characterized as “business income,” subject to taxation in Pennsylvania. Upon review, we affirm the order of the Commonwealth Court.

The parties have stipulated to the relevant facts in this case, which we summarize as follows. See Stipulation of Facts, dated 10/01/10 (hereinafter “Stipulations”). Appellant, a corporation organized…