All Staffing, Inc. v. Commonwealth

OPINION BY

Judge McCULLOUGH.

The Commonwealth of Pennsylvania has filed exceptions to this court’s panel opinion and order, which reversed the April 28, 2006, order of the Board of Finance and Revenue (Board). 1 In our initial opinion we held that All Staffing, Inc. (Taxpayer) did not provide its clients with taxable “help supply services” as that term is defined by section 201 (cc) of the Tax Reform Code of 1971 (Tax Code). 2 After review, we deny the exceptions.

The underlying facts are not in dispute 3 and may be summarized briefly as follows. Taxpayer is a Professional Employer Organization…