McNeil-PPC, Inc. v. Commonwealth

OPINION

Justice NEWMAN.

McNeil-PPC, Inc. (McNeil) appeals from an Order of the Commonwealth Court, denying exceptions McNeil filed to a previous Order of the Commonwealth Court, which affirmed an Order of the Board of Finance and Revenue (BFR) refusing that portion of McNeil’s petition for review of a reassessment of sales and use tax that it paid directly to vendors on non-taxable purchases. For the reasons that follow, we reverse the Order of the Commonwealth Court and hold that an audit requires the Department of Revenue (Department) to correct both underpayments and overpayments of tax for…