PICPA Foundation for Education & Research v. Commonwealth

OPINION ANNOUNCING JUDGMENT OF COURT

ZAPPALA, Justice.

In this direct appeal, we must review the judgment of the Commonwealth Court, 143 Pa.Cmwlth. 291, 598 A.2d 1078 sustaining the decision of the Board of Finance and Review which had denied the request of the PICPA Foundation for Education and Research for a refund of sales tax. Two issues *69are presented by the Appellant. Initially, we must determine whether § 204(10) of the Tax Reform Code of 1971, Act of March 4, 1971, P.L. 6, 72 P.S. § 7204(10) (hereinafter referred to as “Tax Code”), requires “a nonprofit corporation engaged in educational…