OPINION BY PRESIDENT JUDGE BOWMAN, September 4, 1979:
As authorized by Section 763 of the Judicial Code, 42 Pa. C.S. § 763, petitioners seek review of an order of the Board of Finance and Revenue, which sustained a Department of Revenue assessment against petitioners but in doing so declined to rule on a challenge made by petitioners to the constitutionality of Section 314(a) of the Tax Reform Code of 1971 (Code), Act of March 4, 1971, P.L. 6, as amended,...
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