First Federal Savings & Loan Ass'n v. Commonwealth

OPINION

NIX, Chief Justice.

In this appeal we must determine whether interest on tax-exempt Commonwealth obligations held for investment by a mutual thrift institution must be included in that institution’s net income for purposes of the Mutual Thrift Institution Tax Act (“MTITA”), 1 and is thereby subject to taxation.

I

The stipulations agreed to by the parties to this appeal reflect the following pertinent facts. Appellant First Federal Savings and Loan Association of Philadelphia (“First Federal”) is a mutual thrift institution within the meaning of section 2 of the MTITA, 72 P.S. § 1986.2,…