Armco, Inc. v. Commonwealth

SMITH, Judge.

Armco, Inc. (Armco), appeals from the May 31, 1989 order of the Board of Finance and Revenue (Board) which denied Armco’s petition for refund of taxes paid pursuant to Sections 1102-C-1113-C of the Tax Reform Code of 1971 (Realty Transfer Tax Act), Act of March 4,1971, P.L. 6, as amended, 72 P.S. §§ 8102-C — 8113-C. The issue presented to this Court is whether Armco met its burden to prove that a transfer of real property to Armco Advanced Materials Corporation *1192(AAMC)1 was an excluded transaction under the Realty Transfer Tax Act and regulations promulgated thereunder.

The Realty…