Verizon Pennsylvania, Inc. v. Commonwealth

I would affirm the judgment of the Commonwealth Court.

The Tax Reform Code of 1971 (“Code”), by its terms, imposes a tax upon gross receipts from. “telephone messages transmitted.” 72 P.S. § 8101(a)(2). Initially, I agree that directory assistance charges are taxable pursuant to this description, as the information concerning the number sought is transmitted by telephone to the requester. As well, any receipts from the follow-on “ConnectReQuest” service pertain to an essential component of a transmitted message since the customer is only charged if a connection is made. See Majority Opinion,…