Titzel Engineering, Inc. Mercantile Tax Case

Opinion by

Woodside, J.,

We have before us two appeals from orders of the County Court of Allegheny County setting aside mercantile taxes which had been imposed upon Titzel Engineering, Inc. by the City of Pittsburgh and the School District of Pittsburgh. The only question is whether the engineering company (Titzel), a Pennsylvania corporation, was engaged in manufacturing the items for the sale of which the taxes were imposed upon it as a dealer.

The school district assessed its tax under the Act of June 20, 1947, P. L. 745, as amended and re-enacted, 24 P.S. §582.1 et seq., which exempts from…