Commonwealth v. J & R Equipment Rental Co.

Opinion by

Judge Blatt,

J & R Equipment Rental Company, Inc. (J & R) is a Pennsylvania corporation engaged in the business of leasing heavy construction equipment. Five-R Ex*560cavating, Inc. (Five-E) is a Pennsylvania corporation which leases heavy construction equipment from J & E. Both J & E and Five-E were audited by the Department of Eevenue, Bureau of Sales and Use Tax (Bureau) for the period of January 1, 1970 through September 30, 1973. As a result of these audits, the Bureau assessed a sales tax of $13,329.58 plus interest and penalty on J &¡ E and a use tax of $13,353.31 plus interest and…