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DECHERT LLP v. COM.

922 A.2d 87 (2007)

DECHERT LLP, Petitioner, v. COMMONWEALTH of Pennsylvania, Respondent.

Commonwealth Court of Pennsylvania.

Decided April 25, 2007.

Attorney(s) appearing for the Case

David R. Kraus and Randy L. Varner, Harrisburg, for petitioner.

Karen M. Gard, Sr. Deputy Attorney General, Harrisburg, for respondent.

BEFORE: LEADBETTER, President Judge, LEAVITT, Judge, and FLAHERTY, Senior Judge.

OPINION BY President Judge LEADBETTER.

Petitioner Dechert LLP petitions for review of the order of the Board of Finance and Revenue (Board), which denied its request for a refund for sales taxes paid in connection with the purchase of licenses to use computer software during the period November 2, 2000, through December 31, 2003. On appeal, Dechert contends that a license to use software does not constitute "tangible personal property" as that phrase is defined by...

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