Solar Turbines Inc. v. Commonwealth

OPINION BY

Judge FRIEDMAN.

Solar Turbines Incorporated (Solar) petitions for review of the orders of the Board of Finance and Revenue, dated January 24, 2001, which sustained the Department of Revenue’s determinations that Solar is not entitled to refunds of Utilities Gross Receipts Tax (Tax) 1 payments for the years 1997 and 1998. We affirm.

For purposes of this appeal, Solar and the Commonwealth entered into a stipulation of facts, (Solar’s Brief, Ex. A), which are summarized as follows. Solar, a wholly-owned subsidiary of Caterpillar, Inc. (Caterpillar), is a world-wide designer and…