Philadelphia Gas Works Ex Rel. City of Philadelphia v. Commonwealth

MIRARCHI, Senior Judge.

The Philadelphia Gas Works (PGW) appeals from an order of the Board of Finance and Revenue (Board) that affirmed the decision of the Board of Appeals denying PGWs petition for refund, determining that PGW was not entitled to a refund of the sales taxes prepaid to the Commonwealth due to its failure to file the petition for refund within the time period set forth in Section 247 of the Tax Reform Code of 1971 (Tax Code), Act of March 4, 1971, P.L. 6, as amended, 72 P.S. § 7247. We affirm. 1

i.

On appeal, the parties have stipulated to the relevant facts in “Joint…