Commonwealth v. Alcoa Properties, Inc.

Opinion by

Mr. Justice Cohen,

This is an appeal by Alcoa Properties, Inc. (Alcoa) a Delaware corporation authorized to do business in Pennsylvania, from a resettlement of its 1964 Pennsylvania franchise tax. The sole question is whether Alcoa is entitled to exercise the statutory election to compute its tax as a “holding company.” This election provides that a “holding company” may compute tax by applying the tax rate (5 mills in 1964) to ten percent of the actual value of its whole capital stock rather than to a taxable value determined by applying the customary three-fraction formula to the…