Cities Service Oil Co. v. Pittsburgh

Opinion by

Mr. Chief Justice Jones,

Cities Service Oil Company, doing business in the City of Pittsburgh, operated a retail service station at Coltart and Bates Streets and maintained a business office at 32 East Carson Street.1 In April 1957, the City of Pittsburgh and the School District of Pittsburgh audited the records of Cities Service’s business office on Carson Street and assessed mercantile tax deficiencies including penalties and interest totaling $47,-381.65 for the years 1949 through 1952. Cities Service paid this sum, under protest, in June 1957 and prompt*484ly petitioned for a refund…