Philadelphia Suburban Corp. v. Commonwealth

OPINION

NIX, Chief Justice.

This is a tax case. At issue is the validity of a regulation promulgated by the Department of Revenue at 61 Pa.Code § 155.26(b). This Court’s decision will turn on whether the regulation tracks the meaning of the underlying statute. The Commonwealth Court concluded that the regulation was not consistent with the statute, 144 Pa.Commw. 410, 601 A.2d 893. That decision is in error because the Court confined its examination to one isolated portion of the statute while disregarding crucial language expressing a policy judgment to tax corporations precisely as the…