Stewart Honeybee Products, Inc. v. Commonwealth

OPINION

CRUMLISH, Jr., President Judge.

Stewart Honeybee Products, Inc. (Stewart Honeybee) has filed exceptions1 to this Court’s Order2 affirming a Board of Finance and Revenue resettlement which denied Stewart Honeybee an exemption to its capital stock tax assessment.3 We sustain the exceptions.

According to the stipulated facts, Stewart Honeybee, a Pennsylvania corporation, produces marketable honey out of raw honey which is obtained either from its own beehives or purchased from commercial beekeepers. When it arrives at the plant, raw honey is unfit for human consumption—it arrives as a…