Commonwealth v. National Advertising Co.

Opinion by

Mr. Justice Roberts,

This is an appeal1 from the judgment of the Common Pleas Court of Dauphin County, sitting as the Commonwealth Court,2 3affirming the Board of Finance and Revenue’s settlement of appellant’s liability under the *61Corporate Net Income Tax3 for the tax year which terminated December 31, 1963.

The sole question involved here is whether appellant’s receipts from its contracts with advertisers whose advertisements were placed on outdoor billboards situated in this Commonwealth are to be regarded as “rentals . . . from property situated . . . within this Commonwealth” for…