Stewart Honeybee Products, Inc. v. Commonwealth, Board of Finance & Revenue

I dissent, and in support thereof I adopt the erudite opinion authored by President Judge James Crumlish, Jr. of the Commonwealth Court, and liberally quote therefrom as follows:

The Pennsylvania Supreme Court recently refined the definition of manufacturing for purposes of capital stock tax exemption in Ski Roundtop, Inc. v. Commonwealth, *228520 Pa. 227, 553 A.2d 928 (1989). Manufacturing is “(1) the application of labor and skill (2) which changes a material (3) substantially (4) into a new, different and useful item.” Id., 520 Pa. at 231, 553 A.2d at 930.4

Applying that test to these…