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GILBERT ASSOCIATES, INC. v. COM.

498 Pa. 514 (1982)

447 A.2d 944

GILBERT ASSOCIATES, INC., Appellant, v. COMMONWEALTH of Pennsylvania.

Supreme Court of Pennsylvania.

Decided June 28, 1982.

Attorney(s) appearing for the Case

Harry J. Rubin, Harrisburg, for appellant.

Vincent J. Dopko, Deputy Atty. Gen., Harrisburg, for appellee.

Before O'BRIEN, C.J., and ROBERTS, NIX, LARSEN, FLAHERTY, McDERMOTT and HUTCHINSON, JJ.

OPINION OF THE COURT

ROBERTS, Justice.

Appellant, Gilbert Associates, Inc., is a Delaware corporation authorized to do business in Pennsylvania. As a foreign corporation earning taxable income within and without the Commonwealth of Pennsylvania, appellant is required to pay a franchise tax pursuant to a three-factor formula that is designed to apportion the value of its capital stock attributable to its activities in Pennsylvania. Tax Reform Code of 1971...

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