Ski Roundtop, Inc. v. Commonwealth

OPINION ANNOUNCING THE JUDGMENT OF THE COURT

FLAHERTY, Justice.

Pennsylvania imposes a capital stock tax upon certain business entities, but exempts from taxation those “orga*229nized for manufacturing, processing, research or development purposes____” The Capital Stock Tax Act of March 4, 1971, P.L. 6, No. 2, art. VI, § 602, 72 P.S. § 7602. The issue presented in this case is whether Ski Roundtop, the taxpayer, should be partially exempted from the capital stock tax under the manufacturing exemption on the theory that some of its otherwise taxable assets are used in a manufacturing process.

The…