Pennsylvania Statutes Title 72 P.S. Taxation and Fiscal Affairs § 8103-A. Assessment;  collection

(a) The department shall make all inquiries, determinations and assessments of tax, interest, additions and penalties necessary to enforce this article.

(b) The provisions of sections 337 through 345   1 shall apply to the assessment and collection of public utility realty tax under this article.  A public utility shall not raise a defense or objection in a proceeding that could have been presented as part of an administrative or judicial remedy under section 1105-A or 1109-A.  2

(c) The amount of any tax or penalty imposed under this article shall be assessed within three years after the close of the taxable year or within one year of a final determination resulting from the public utility's appeal under section 1105-A, whichever is later.