Tranel, Inc. v. Commonwealth

NARICK, Senior Judge.

Tranel, Inc. (Taxpayer) has petitioned for review of an order of the Board of Finance and Revenue denying its petition to resettle its Pennsylvania corporate income tax for the fiscal year ending August 31,1972 (1972 fiscal year).

The parties have filed a detailed stipulation of facts, which we shall briefly summarize. Taxpayer is a New York corporation which owns two principal assets, a high-rise office building in New York and a high-rise office building in Philadelphia. For the 1972 fiscal year, it reported taxable income of $2,024.19 from the Pennsylvania building,…