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MISSION FUNDING ALPHA v. COMMONWEALTH

No. 2 MAP 2016.

173 A.3d 748 (2017)

MISSION FUNDING ALPHA, Appellee v. COMMONWEALTH of Pennsylvania, Appellant.

Supreme Court of Pennsylvania.

Decided: November 22, 2017.

Attorney(s) appearing for the Case

Paul Evan Melniczak, Esq. , Kyle Oliver Sollie, Esq. , Reed Smith LLP, for Appellee.

Bruce Richard Beemer, Esq. , John G. Knorr III, Esq. , Neil Patrick McConnell, Esq. , Pennsylvania Office of Attorney General, Joshua D. Shapiro, Esq. , Carol L. Weitzel, Esq. , PA Office of Attorney General, for Appellant.

Jeffrey T. McGuire, Esq. Cipriani & Werner, P.C., for Amicus Curiae The Pennsylvania Institute of Certified Public Accountants.

SAYLOR, C.J., BAER, TODD, DONOHUE, DOUGHERTY, WECHT, MUNDY, JJ.

OPINION

We consider the Commonwealth Court's decision that the three-year tax refund period specified in Section 3003.1(a) of the Tax Reform Code of 1971 (Tax Code), 72 P.S. § 10003.1(a), begins to run on the date the corporate taxpayer files its...

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