Mission Funding Alpha v. Commonwealth, Aplt.

OPINION

JUSTICE DOUGHERTY

We consider the Commonwealth Court’s decision that the three-year tax refund period specified in Section 3003.1(a) of the Tax Reform Code of 1971 (Tax Code), 72 P.S. § 10003.1(a), begins to run on the date the corporate taxpayer files its annual tax report. We hold the Commonwealth Court erred in so holding under the circumstances of this case, and therefore reverse and remand.

Appellee, Mission Funding Alpha, is a calendar-year . taxpayer that conducted business in the Commonwealth of Pennsylvania during the year ending December 31, 2007 (2007 Tax Year), and pursuant…