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Ikon Office Solutions, Inc. v. City of Pittsburgh

Plaintiff was not entitled to a refund of business privilege taxes based on the manufacturer exemption contained in the Local Tax Enabling Act (LTEA) because plaintiff's photocopying activities create no more than a superficial change in the original materials and do not constitute manufacturing as that term is used in the LTEA.

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Argued: February 6, 2001

The City of Pittsburgh appeals the order of the Court of Common Pleas of Allegheny County sustaining Ikon Office Solutions’ statutory appeal of the City Treasurer’s denial of its request for refund of business privilege taxes for the tax years 1993 through 1997. Ikon contends that it is not subject to the City’s business privilege tax because its activities constitute manufacturing within the meaning of Section 2(4) of The Local Tx Enabling Act (LTEA).*fn1

Alco Office Systems, renamed Ikon Office Solutions, and doing business as NightRider, requested the refund of business privilege taxes for the tax years 1993 through 1997. When the requests were denied, Ikon requested a Treasurer’s Hearing. The undisputed facts of this case, as found by the City Treasurer, are summarized as follows.

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