Spang Stores, Inc. v. Commonwealth

*65OPINION

JONES, Chief Justice.

Appellant, Spang Stores, Inc., appeals 1 the decision of the Commonwealth Court which appraised the actual value of the capital stock of the appellant for the year ended January 31, 1971, pursuant to the Capital Stock Tax,2 at $2,000,000. 17 Pa.Cmwlth. 448, 333 A.2d 493 (1975).

The taxpayer is a Pennsylvania Corporation engaged in the operation of fifty-nine retail drugstores under the name Sun Drug and five discount stores under the name of Eiben & Irr, all located in western Pennsylvania, with a major concentration of stores in the Pittsburgh metropolitan area.

Taxp…