Tool Sales & Service Co. v. Commonwealth

McGINLEY, Judge.

Tool Sales and Service Company, Inc. and Tom Mistick and Sons, Inc. (collectively Taxpayers) appeal orders entered by the Board of Finance and Revenue (Board) that disallowed a deduction representing hypothetical federal tax liability in calculation of Taxpayers’ capital stock value for tax purposes in the years 1984 and 1985. We affirm.

The parties have stipulated to the following facts. Taxpayers qualify for S corporation treatment under federal and state tax laws. 1 During the years in question, Taxpayers were S corporations for both state and federal purposes. Although not…