Aldine Apartments, Inc. v. Commonwealth

I dissent. The majority misconstrues the statute, ignoring the legislative mandate that taxing statutes “shall be strictly construed.” Statutory Construction Act of 1972, 1 Pa.C. S.A. § 1928(b)(3) (Supp.1964-1979); See Estate of Carlson, 479 Pa. 421, 424, 388 A.2d 726, 728 (1978) (“A taxing statute *489must not only be strictly construed, but all reasonable doubt must be resolved in favor of the taxpayer.”) This principle of construction is particularly compelling in times when taxation and inflation ravage taxpayers.

The Tax Reform Code of 1971, 72 P.S. § 7202(a) imposes a six percent sales tax…