Wilmington Trust Corp. v. Commonwealth

OPINION BY

Judge McGINLEY.

Wilmington Trust Corporation (Petitioner) petitions for review of the Order issued by the Board of Finance and Revenue (Board) on September 18, 2001, sustaining the Department of Revenue’s (Department) assessment of its tax liability for the year ending December 31, 1998.

The single issue on appeal is whether Petitioner, a foreign corporation that elected to compute its tax liability using the single-factor apportionment formula 1 , is entitled to prorate its tax for the period from January 1, 1998, to March 1, 1998?

The following facts have been stipulated to by both…