Stewart Honeybee Products, Inc. v. Commonwealth

Opinion by

Judge Palladino,

In this consolidated appeal, Stewart Honeybee Products, Inc. (Petitioner) appeals from an order and a resettlement of the Board of Finance and Revenue *432which determined that Petitioner was not entitled to the manufacturing exemption from capital stock tax for the tax years ending June 30, 1980 and June 30, 1981, respectively. For the reasons set forth below, we affirm.

Petitioner is a Pennsylvania corporation engaged in the business of producing honey for human consumption. Petitioner obtains raw honey from its beehives and purchases raw honey from other beekeepers.…