dissenting.
I dissent. The appellant corporation clearly fulfills the requirements of the “family farm corporation” exemption *475from the Pennsylvania Capital Stock Tax. The exemption defines “family farm corporation” as a “Pennsylvania corporation at least seventy-five per cent of the assets of which are devoted to the business of agriculture____” 72 P.S. § 7602.2 (emphasis added). There can be no question that the assets of the appellant corporation, to wit farmland and farm machinery, are devoted to the business of agriculture. The fact that the assets are leased to others who perform the actual farm work is immaterial, for the assets are still devoted to the business of agriculture. There is no language in the exemption to indicate that the legislature intended to limit the exemption so as to apply only to assets which are not leased. Indeed, the leasing of equipment and farmland is such a well-known common practice in the agricultural community that, had the legislature intended to regard such assets as not being devoted to the business of agriculture, the legislature surely would have so stated.
This dissenting opinion is joined by LARSEN, J.