OPINION OF THE COURT
LARSEN, Justice.
The facts have been stipulated in this case and are essentially as follows: appellant, Leroy S. Lapp, is the sole proprietor of a painting and sandblasting business located in Parksburg (Chester County), Pennsylvania. Pursuant to the Tax Reform Code of 1971 (TRC), 72 P.S. § 7319(3) (Supp. 1979-80), appellant is required to pay over on a semi-monthly basis to the Commonwealth of Pennsylvania (appellee) the personal...
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