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DEPT. OF REVENUE v. TAX REVIEW BD.

157 Pa.Commw. 43 (1993)

628 A.2d 1220

CITY OF PHILADELPHIA, DEPARTMENT OF REVENUE, Appellant, v. TAX REVIEW BOARD OF the CITY OF PHILADELPHIA TO the USE OF SAWIN SYSTEMS, INC.

Commonwealth Court of Pennsylvania.

Decided July 9, 1993.

Attorney(s) appearing for the Case

Joseph F. Lynch, Asst. City Sol., for appellant.

Berle M. Schiller, for appellee.

Before PALLADINO, FRIEDMAN and KELLEY, JJ.

PALLADINO, Judge.

City of Philadelphia (City) appeals from an order of the Court of Common Pleas of Philadelphia County (trial court) affirming the decision of the City's Tax Review Board (Board) that Sawin Systems, Inc. (Taxpayer) is a manufacturer for purposes of assessing Mercantile License Tax (MLT) and Business Privilege Tax (BPT) and that, to the extent that Taxpayer delivers its product to customers outside the city

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