Commonwealth v. Deitch Co.

Opinion by

Mb. Justice Eagen,

The principal narrow issue for decision in this case is whether the operations of a scrap metal dealer come within the manufacturing exemption of the Capital Stock Tax Act of June 1, 1889, P. L. 420, as amended, 72 P.S. §1871. Although the manufacturing exemption has generated a substantial amount of litigation over the years, the case is a novel one in that we have never passed on whether scrap metal dealers are within the exemption’s compass.

During the calendar year in question, the Capital Stock Tax Act, supra, imposed on domestic corporations a tax at the rate…