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FEDEX GROUND PACKAGE SYSTEM, INC. v. COM.

898 A.2d 22 (2006)

FEDEX GROUND PACKAGE SYSTEM, INC., Petitioner v. COMMONWEALTH of Pennsylvania, Respondent.

Commonwealth Court of Pennsylvania.

Decided April 17, 2006.

Attorney(s) appearing for the Case

David J. Gutowski and Lee A. Zoeller, Philadelphia, for petitioner.

Michael A. Roman, Sr. Deputy Attorney General, Harrisburg, for respondent.

BEFORE: McGINLEY, Judge, SMITH-RIBNER, Judge, and FLAHERTY, Senior Judge.

OPINION BY Judge McGINLEY.

Taxpayer, FedEx Ground Packaging System, Inc. (Petitioner) petitions for review of the Board of Finance and Revenue's (Board) denial of its petitions for refunds of corporate net income and franchise taxes for the tax year ended May 31, 1999. Specifically, the issue involves the revenue miles apportionment fraction used to apportion Petitioner's taxable income and value in Pennsylvania.

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