Valentine Co. v. Commonwealth

OPINION BY

President Judge LEADBETTER.

Valentine Company, Inc. (f/k/a Nichols & Associates, Inc.), a licensed surplus lines licensee for Temple University,1 has filed exceptions to this court’s panel opinion and order, which affirmed as modified the Board of Finance and Revenue’s denial of its petition for relief.2 In our initial opinion, we concluded that Temple University was not immune from the 3% surplus lines tax obligation imposed pursuant to Article XVI of The Insurance Company Law of 1921 (commonly referred to as the Surplus Lines Act)3 on premiums that Temple paid to a surplus lines…