Consolidated Rail Corp. v. Commonwealth

RODGERS,1 Senior Judge.

Consolidated Rail Corporation (Conrail) appeals from three orders of the Pennsylvania Board of Finance and Revenue (Board) refusing Conrail’s petitions for review of the Pennsylvania Department of Revenue’s (Department) determination of its capital stock tax (CST) obligations for the taxable years *724January 1 through April 2, 1987, April 3 through April 30, 1987 and May 1, 1987 through April 30,1988. We affirm.

Conrail was incorporated in Pennsylvania on February 10, 1976.2 Prior to April 2,1987, eighty-five percent of Conrail’s stock was owned by the United States; the…