OPINION OF THE COURT
FLAHERTY, Justice.
The Capital Stock Tax imposes a tax liability on certain business entities in Pennsylvania, but exempts, inter alia, manufacturers. Act of March 4, 1971, P.L. 6, No. 2, art. VI, § 602 as amended, 72 P.S. § 7602. Stewart Honeybee, the taxpayer herein, claimed that it was entitled to the manufacturing exemption for the years 1980 and 1981, and sought review before Commonwealth Court of the decisions of the...
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