Stewart Honeybee Products, Inc. v. Commonwealth

I must respectfully dissent. On August 8, 1988, in Stewart Honeybee Products, Inc. v. Commonwealth, 118 Pa. Commonwealth Ct. 430, 545 A.2d 468 (1988) (Stewart Honeybee I), a unanimous panel of this court held that the process used to refine the honey in this matter did not constitute manufacturing under the capital stock tax, Act of March 4, 1971, P.L. 6, as amended, 72 P.S, § 7602. Petitioner’s exceptions have provided no new authority to support the reversal of Stewart Honeybee I.

*137While the majority opinion correctly sets forth the test for determining whether a process is manufacturing, it…