Systems & Computer Technology Corp. v. Commonwealth

OPINION BY

President Judge LEADBETTER. 1

Systems & Computer Technology Corporation (SCT) petitions to review the or der of the Board of Finance and Revenue that affirmed the Board of Appeals’ resettlement of SCT’s franchise tax liability for the taxable year 2005. In this appeal, the Court is asked to decide whether the “goodwill” recorded on SCT’s 2005 balance sheet as an asset is includable in “the actual value” of its stock in its wholly owned subsidiary corporations. If so, SCT is eligible to compute its 2005 franchise tax liability utilizing the favorable “10% holding company…