City of Philadelphia v. Tax Review Board ex rel. Sawin Systems, Inc.

PALLADINO, Judge.

City of Philadelphia (City) appeals from an order of the Court of Common Pleas of Philadelphia County (trial court) affirming the decision of the City’s Tax Review Board (Board) that Sawin Systems, Inc. (Taxpayer) is a manufacturer for purposes of assessing Mercantile License Tax (MLT) and Business Privilege Tax (BPT) and that, to the extent that Taxpayer delivers its product to customers outside the city *45limits, the receipts therefrom are excludable from its taxable receipts. We affirm.

I. The Production Process

Taxpayer is in the business of producing a plastic film or…