Rosetta Oil, Inc. v. Commonwealth

FRIEDMAN, Judge.

Rosetta Oil, Inc. (Rosetta) appeals from an order of the Board of Finance and Revenue (Board) denying Rosetta’s Petition for Review of the Department of Revenue’s (Department) assessment of Liquid Fuels Taxes against Rosetta from January 1988 through July 1988.

Since 1985, Rosetta has engaged in the retail and commercial heating oil, heating and air conditioning business. (Tr. at 42.)1 In January of 1988, Rosetta was asked by its then-lender, Meridian Bank, to allow Bell Fuel Company (Bell), another Meridian customer in the liquid fuel business, to use Rosetta’s credit to…