OPINION OF THE COURT
ROBERTS, Justice.
Appellant Greenville Steel Car Company is a Pennsylvania corporation which manufactures, sells and leases railroad cars and earth moving equipment. Appellant elected to be treated as a foreign corporation for purposes of paying the capital stock tax for the taxable year ending December 31, 1971. See § 602(a) of the Tax Reform Code of 1971, Act of March 4, 1971, P.L. 6, art. VI, § 602(a) as amended, 72 P.S...
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