SMITH, Judge.
Gilmour Manufacturing Company (Gilmour) petitions for review of an order of the Board of Finance and Revenue (Board) that denied Gilmour's petition for a refund of a portion of its 1991 corporate net income (CNI) tax. The sole question presented is whether Gilmour's 1991 CNI tax should be calculated by including sales to purchasers not located in Pennsylvania who pick up the
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