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  5. 88 Pa.Commw. 184 (1985)
 

C. C. COLLINGS & CO., INC. v. COM.

Nos. 1584 C.D. 1982, 1585 C.D. 1982, 1027 C.D. 1982, 1028 C.D. 1982, 2125 C.D. 1981 and 2403 C.D. 1981.

88 Pa.Commw. 184 (1985)

C. C. Collings & Co., Inc., Petitioner v. Commonwealth of Pennsylvania, Respondent. C. C. Collings & Company, Inc., Petitioner v. Commonwealth of Pennsylvania, Respondent. A. E. Masten & Company, Inc., Petitioner v. Commonwealth of Pennsylvania, Respondent. A. E. Masten & Company, Inc., Petitioner v. Commonwealth of Pennsylvania, Respondent. Commonwealth Securities & Investments, Inc. (formerly Henry Fisher & Co., Inc., d/b/a Henry Fisher Municipals), Petitioner v. Commonwealth of Pennsylvania, Respondent. Commonwealth Securities & Investments, Inc. (formerly Henry Fisher & Co., Inc., d/b/a Henry Fisher Municipals), Petitioner v. Commonwealth of Pennsylvania, Respondent.

Commonwealth Court of Pennsylvania.

March 6, 1985.

Attorney(s) appearing for the Case

P. J. Di Quinzio, with him, Francis Mazzola and Eileen Kennedy, Dechert, Price & Rhoads, for petitioner, C. C. Collings & Co., Inc.

Foster S. Goldman, Jr., with him, Robert T. Harper and Robert W. Thomas, Berkman, Ruslander, Pohl, Lieber & Engel, for petitioner, A. E. Masten & Company, Inc.

John D. O'Brien, O'Brien & Friedlander, for petitioner, Commonwealth Securities & Investments, Inc. (formerly Henry Fisher & Co., Inc., d/b/a Henry Fisher Municipals).

Paul S. Roeder, Deputy Attorney General, with him, Michael A. Roman, Deputy Attorney General, and LeRoy S. Zimmerman, Attorney General, for respondent.

Argued October 16, 1984, before President Judge CRUMLISH, JR. and Judges ROGERS, WILLIAMS, JR., MacPHAIL, DOYLE, BARRY and COLINS.

OPINION BY JUDGE ROGERS, March 6, 1985:

In these consolidated appeals,1 a number of the Commonwealth's corporate taxpayers engaged in the business of underwriting and trading in municipal obligations seek review of orders of the Board of Finance and Revenue which orders sustained the action of the Department of Revenue in disallowing in the 1978-79 tax years a deduction

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