Unisys Corp. v. Commonwealth

While I agree with that portion of the majority’s decision concluding that the apportionment formula used by the Department of Finance and Revenue (Department) to calculate Unisys Corporations’ (Unisys) franchise taxes complied with due process, I dissent from that portion of the majority’s opinion that the disparity between the calculations of Unisys’ allocated and actual shares was sufficient reason to require the Department to afford Unisys equitable relief under Section 401(3)2.(a)(18) of the Tax Reform Code of 19711 (referred to herein as Subsection 18). I disagree because I believe that…