Fiore v. Commonwealth

NARICK, Senior Judge.

This ease is before us on remand from the Supreme Court of Pennsylvania which vacated this Court’s order of tax deficiency and ordered a new hearing before this Court. The basis for this order was that William Fiore, t/d/b/a Fiore Trucking and Contract*1212ing (Taxpayer) had been denied procedural due process when this Court permitted the Commonwealth of Pennsylvania (Commonwealth) to assert new legal theories regarding Taxpayer’s liability for the tax assessments just weeks before the hearing before this Court (Hearing I), thus forcing the Taxpayer to justify his exemption…