Commonwealth v. Atlantic & Gulf Coast Stevedores, Inc.

Opinion by

Mr. Justice Cohen,

Atlantic & Gulf Coast Stevedores, Inc. (Atlantic) filed corporation income tax returns for the years 1955 *443through 1961 with the Commonwealth of Pennsylvania denying any liability for tax on the ground that it was engaged exclusively in interstate and foreign commerce and was, therefore, exempt from taxation by the State. '.The Commonwealth’s tax officials rejected Atlantic’s contention and made settlements imposing tax for each year, duly notifying Atlantic. Atlantic ignored the notices and filed no petitions for resettlement.

On April 5, 1965, the settlements…