197 Pa. 551 | Pa. | 1901
Opinion by
The capital stock of the Pennsylvania Coal Company was appraised at $17,000,000 for the purpose of taxation. From this sum certain deductions were allowed by the commonwealth, leaving the taxable value of the stock at $¡15,840,000, and from this still further deductions or exemptions are claimed by the appellant. Capital stock tax is a property tax, but the property of the corporation, for the purpose of taxation, is reached through the tax imposed directly upon the stock, the value of which is ascertained, in the first instance, as directed by the act of assembly. When the actual value of the capital stock is so ascertained, deductions or exemptions are necessarily allowed, from time to time, by the commonwealth in determining the real sum upon which the tax ought to be assessed against the corporation ; and the questions raised on this appeal are, whether the mortgages on property outside the state, and the coal shipped to foreign points, should be taxed, or deductions allowed on their account.
The two claims for exemption pressed by the appellant are
The mortgages held by the appellant for the unpaid purchase moneys for properties sold by it in New York and New Jersey,