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  5. 948 A.2d 790 (2008)
 

PA BANKERS ASS'N v. PA DEPT. OF BANKING

Nos. 35 MAP 2006, 36 MAP 2006.

948 A.2d 790 (2008)

PENNSYLVANIA BANKERS ASSOCIATION and the Pennsylvania Business Bank, Appellants v. PENNSYLVANIA DEPARTMENT OF BANKING and Trumark Financial Credit Union, Appellees. Pennsylvania Bankers Association, Pennsylvania Business Bank, Fulton Bank, and Premier Bank, Appellants v. Pennsylvania Department of Banking, Pennsylvania Department of Revenue, the Attorney General of the Commonwealth and Freedom Credit Union, Appellees.

Supreme Court of Pennsylvania.

Re-Submitted January 11, 2008.

Decided June 16, 2008.

Attorney(s) appearing for the Case

Christopher R. Nestor, Esq., Raymond P. Pepe, Esq., Kirkpatrick & Lockhart Preston Gates Ellis, L.L.P., Harrisburg, for Pennsylvania Bankers Association, et al.

Francis Crowley, Esq., Philadelphia, for Freedom Credit Union.

Victoria Ann Reider, Esq., Linda Carroll, Esq., for Pennsylvania Department of Banking.

Daniel T. Fitch, Esq., Philadelphia, Trumark Financial Credit Union.

Richard T. Wargo, Jr., Esq., PA Credit Union Association, for Pennsylvania Credit Union Association.

Howard G. Hopkirk, Esq., Harrisburg, for Attorney General's Office and Dept. of Revenue.

BEFORE: CASTILLE, C.J., and SAYLOR, EAKIN, BAER, TODD and McCAFFERY, JJ.

OPINION

Justice BAER.1

This direct appeal arises from a procedurally complex dispute between various members of the banking industry, the credit union industry, and several administrative agencies, concerning the tax treatment of credit unions under the Pennsylvania Credit Union Code ("Credit Union Code"), 17 Pa.C.S. §§ 101-1504. At issue is whether the Commonwealth...

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