Commonwealth v. J. L. Mott Corp.

OPINION OF THE COURT

ROBERTS, Justice.

This is an appeal from the decision of the Commonwealth Court dismissing an appeal from the denial by the Board of Finance and Revenue of a petition for review of the settlement of appellant’s 1962 franchise tax and entering a judgment in favor of the Commonwealth for $824. A portion of appellant’s gross receipts is rent paid by tenants who lease manufacturing plants from appellant. The sole issue in this appeal is whether the manufacturer’s exemption contained in the franchise tax entitles appellant to exclude those rents from the numerator of the gross…