Department of Labor & Industry v. New Enterprise Rural Electric Cooperative, Inc.

Opinion by

Mr. Justice Patterson,

This appeal by the Commonwealth raises the following issue: are unemployment compensation contribu tiong taxes within the meaning of Section 31 of the Electric Cooperative Corporation Act of 1937 which provides “Corporations formed hereunder shall pay annually, on or before July first, to the Department of Revenue, a fee of ten dollars ($10) for each one hundred members, or fraction thereof, but shall be exempt from all other State taxes of whatsoever kind or nature.”

New Enterprise Rural Electric Cooperative, Inc., appellee, was incorporated November 18, 1938,…