Royal Bank of Pennsylvania v. Commonwealth

PELLEGRINI Judge.

Royal Bank of Pennsylvania (Taxpayer) appeals an order of the Board of Finance and Revenue (Board) denying its request for a refund of bank shares taxes it paid to the Commonwealth of Pennsylvania (Commonwealth) for tax year 1989.1

The dispute underlying this appeal, with various twists and turns, stems from a decision of the United States Supreme Court in American Bank and Trust Co. v. Dallas County, 463 U.S. 855, 103 S.Ct. 3369, 77 L.Ed.2d 1072, rehearing denied, 463 U.S. 1250, 104 S.Ct. 39, 77 L.Ed.2d 1457 (1983). In that case, the United States Supreme Court held that bank…