Commonwealth v. Perfect Photo, Inc.

Opinion by

Judge Mencer,

As we focus in upon the issue of this appeal, we discern a visible image of a photofinisher seeking a ruling that it is engaged in manufacturing and therefore exempt from capital stock taxation under Section 21 of the Capital Stock Tax Act of June 1, 1889, P.L. 420, as amended (Act).1 Perfect Photo, Incorporated (taxpayer) contests a decision of the Board of Finance *318and Revenue which sustained a resettlement by the Department of Revenue of the taxpayer’s capital stock tax for the fiscal year ended March 31, 1966.2

We make the following

Findings on Fact

1. Taxpayer was…