Dechert LLP v. Commonwealth

OPINION BY

President Judge LEADBETTER.

Petitioner Dechert LLP petitions for review of the order of the Board of Finance and Revenue (Board), which denied its request for a refund for sales taxes paid in connection with the purchase of licenses to use computer software during the period November 2, 2000, through December 31, 2008. On appeal, Dechert contends that a license to use software does not constitute “tangible personal property” as that phrase is defined by Section 201(m) of the Tax Reform Code of 1971 (Code), Act of March 4, 1971, P.L. 6, as amended, 72 P.S. § 7201(m) and, therefore, is…