UPS Worldwide Forwarding, Inc. v. Commonwealth

OPINION BY

Senior Judge FLAHERTY.

UPS Worldwide Forwarding, Inc. (Taxpayer) appeals from four orders of the Board of Finance and Revenue (Board) which refused Taxpayer’s request to have its Corporate Net Income Tax (CNI Tax) and Franchise Tax for the years 1996 and 1997 recalculated by including a payroll factor along with the property factor and sales factor in the tax apportionment formula found in the Tax Reform Code of 1971 (Tax Reform Code). 1 We affirm.

Initially, we note that the Franchise Tax is not a tax on property or capital assets, but a tax on the privilege of doing business in…