FedEx Ground Package System, Inc. v. Commonwealth

OPINION BY

Judge McGINLEY.

Taxpayer, FedEx Ground Packaging System, Inc. (Petitioner) petitions for review of the Board of Finance and Reve nue’s (Board) denial of its petitions for refunds of corporate net income and franchise taxes for the tax year ended May 31, 1999. Specifically, the issue involves the revenue miles apportionment fraction used to apportion Petitioner’s taxable income and value in Pennsylvania.

The relevant facts as stipulated are as follows: Petitioner is a Delaware Corporation headquartered in Moon Township, Pennsylvania. Petitioner is engaged in the business of…