Orsato-Guenon, Inc. v. Commonwealth

DOYLE, Judge.

Orsato-Guenon, Inc. (Taxpayer) appeals from an order of the Board of Finance and Revenue which denied Taxpayer’s petition to review an assessment of corporate net income tax by the Department of Revenue.

The parties stipulated to the following facts. Taxpayer was incorporated as a Pennsylvania corporation on November 7, 1985, and was engaged in real estate activities until January 1, 1991. Taxpayer was owned by *521four individual stockholders1 until the corporation was dissolved on February 1, 1991.

When Taxpayer was incorporated it elected subchapter S status under the federal…