SUN OIL CO. v. TAX REVIEW BOARD


417 Pa. 443 (1965)

Sun Oil Company, Appellant, v. Tax Review Board. Sun Oil Company, Appellant, v. Philadelphia School District.

Supreme Court of Pennsylvania.

March 16, 1965.


Attorney(s) appearing for the Case

James A. Moore, with him Milton P. King, Carter Bledsoe, and Mancill, Sterling, Magaziner, Seamans & Hedges, and Pepper, Hamilton & Scheetz, for appellant.

Joseph W. Marshall, for School District of Philadelphia, appellee.

Levy Anderson, First Deputy City Solicitor, with him Louis Kattelman, Assistant City Solicitor, Matthew W. Bullock, Jr., Deputy City Solicitor, and Edward G. Bauer, Jr., City Solicitor, for Tax Review Board, appellee.

Before BELL, C.J., MUSMANNO, JONES, COHEN, EAGEN, O'BRIEN and ROBERTS, JJ.


OPINION BY MR. JUSTICE O'BRIEN, March 16, 1965:

Sun Oil Company appeals from holdings below, ruling as taxable Sun's receipts of dividend income derived from its ownership of certain common stocks, as well as a substantial capital gain realized from the sale of one of these stock holdings.

Two separate taxes are involved, the first being the General Business Tax Act, Act of May 23, 1949, P.L. 1669, as amended, 24 P.S. § 584.1 et seq., imposing a tax on...

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