OPINION OF THE COURT
FLAHERTY, Justice.
In this case we are asked to determine whether an operator who sinks coal mine shafts and drives coal mine slopes for a soft coal extractor is engaged in the "manufacture" of personal property as that term is defined in the Tax Reform Code of 1971, 72 P.S. § 7201 et seq. The Commonwealth Court, in an appeal from an order of the Board of Finance and Revenue denying a refund to the taxpayer, issued a final order...
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