OPINION BY Judge PELLEGRINI.
Glatfelter Pulpwood Company (Taxpayer) petitions for review from an order of the Board of Finance and Revenue (Board) denying its request for a tax refund because its timberland sales gains meets the definition of "business income" under Section 401(3)2.(a)(1)(A) of the Tax Reform Code of 1971.
I.
According to the parties' Stipulation...
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