Commonwealth v. A. J. Wood Research Co.

Opinion by

Judge Craig,

In these two consolidated appeals by the Commonwealth from a sales tax reassessment and use tax refund granted by the Board of Finance and Revenue (Board) in favor of taxpayer A. J. Wood Research Company of Pennsylvania, trading as Computer Letters, Inc., the central common issue is

Does the taxpayer’s use of computerized word processing equipment to produce a large number of letters and other materials, for distribution as direct mail advertising, fall within the printing exclusion of the Tax Reform Code of 1971 (Tax Code)?1

Tax Code §201(o) (4) (B) (i), as to use tax,…