Commonwealth v. Mellon National Bank & Trust Co.

Opinion by

Mr. Justice Cohen,

This is an appeal by Mellon National Bank and Trust Company (Mellon) with respect to its shares tax report for the year 1959. The shares tax is imposed by the Act of July 15, 1897, P. L. 292, as amended, 72 P.S. §1931, and is “at the rate of eight mills upon each dollar of the actual value” of the shares.

In computing its shares tax for 1959,1 Mellon added its capital stock, surplus and undivided profits as shown on its books. To this it added its federal tax reserve for losses on loans and discounts and arrived at a total of $306,541,525.84. Mellon then subtracted…