Morrisville Scrap Processing Co., Inc. Tax Appeal

Opinion by

Judge Rogers,

In this case, a dealer in scrap metal seeks a decision that it is engaged in manufacturing and therefore exempt from capital stock taxation, under the Capital Stock Tax Act, Act of June 1, 1889, P. L. 420, as amended, 72 P.S. 1871.1

The Commonwealth assessed the capital stock tax against the appellant for its fiscal year ending September 80, 1969, although the Act provided that it should “. . . not apply to the taxation of the capital stock of corporations . . . which is invested in and actually and exclusively employed in carrying on manufacturing . . . within the…