American Electric Power Service Corporation v. Commonwealth of PA

OPINION BY PRESIDENT JUDGE LEAVITT

Before the Court are exceptions filed by American Electric Power Service Corporation (Taxpayer) 1 to an opinion and order of a three-judge panel of this Court dated May 4, 2017, which affirmed the Board of Finance and Revenue (Board). See American Electric Power Service Corporation v. Commonwealth , 160 A.3d 950 (Pa. Cmwlth. 2017) ( American Electric Power I ). In doing so, the panel held that Taxpayer's sale of electricity to the Letterkenny Industrial Development Authority (LIDA) is subject to the gross receipts tax set forth in Section 1101(b) of the Tax…