Com. v. Olan Mills, Inc. of Ohio

Dissenting Opinion by

Mr. Justice Roberts :

Anyone who ever snapped the shutter of a camera would be surprised indeed to learn that, in the majority’s view, he is engaged in “manufacturing.” The majority reaches its result by holding the mere exposure of film to be “manufacturing.” Accordingly, the Commonwealth by today’s decision is precluded from imposing tax1 on the use by appellant within this state of film and specialized cameras.

I dissent and would affirm the order of the Commonwealth Court. In my view, the principles enunciated in Commonwealth v. Deitch Co., 449 Pa. 88, 295 A.2d 834…