Bell Atlantic Mobile Systems, Inc. v. Commonwealth

OPINION BY

Judge McGINLEY.

Bell Atlantic Mobile Systems, Inc. (Bell) and AWACS, Inc. (AWACS) (collectively, Taxpayer) petition for review 1 from an order of the Pennsylvania Board of Finance and Revenue (Board) that reassessed the sales and use tax and interest against Bell and sustained the decision of the Board of Appeals' assessment against AWACS.

Taxpayer and the Commonwealth of Pennsylvania (Commonwealth) stipulated to the following:

2. Taxpayer is a for-profit corporation engaged in the business of producing and selling mobile domestic cellular radio telecommunications service, sometimes…