Commonwealth v. Lohmann-Johnson Oil Co.

Opinion by

Mr. Justice Cohen,

This appeal involves the corporate net income tax of the Lohmann-Johnson Oil Co., Inc., for the year ended April 30, 1963. The company (appellant) is a Pennsylvania corporation located in Pittsburgh and engaged in the business of drilling for oil and gas under contracts with other parties. These contracts are negotiated on appellant’s behalf by employees located at its Pittsburgh office; but the work itself is performed in three different states: Pennsylvania, Maryland and West Virginia.

In reporting its corporate net income tax for the year ended April 30, 1963,…