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ALLFIRST BANK v. COM.

Nos. 82 MAP 2006, 83 MAP 2006.

933 A.2d 75 (2007)

ALLFIRST BANK, Appellant v. COMMONWEALTH of Pennsylvania, Appellee Allfirst Bank, Appellant v. Commonwealth of Pennsylvania, Appellee.

Supreme Court of Pennsylvania.

Decided October 17, 2007.

Attorney(s) appearing for the Case

Gregory James Krock, Jeffrey S. Blum, Buchanan Ingersoll & Rooney, P.C., Pittsburgh, for Allfirst Bank, appellant.

Carol L. Weitzel, Thomas W. Corbett, Michael Adam Roman, PA Office of Atty. Gen., for the Com of Pa, appellee.

Before CAPPY, C.J., CASTILLE, SAYLOR, EAKIN, BAER and BALDWIN, JJ.

OPINION

Justice SAYLOR.

These direct appeals involve the issue of whether Pennsylvania's bank and trust company shares tax is a tax levied against the financial institution itself, or a personal property tax imposed on its shareholders.

Banking institutions in Pennsylvania are exempt from both the capital stock/franchise tax and the corporate net income tax. See 72 P.S. §§ 7402(c), 7602(i).1 However...

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