purpose than the standard advanced by the majority, as with the majority’s standard, it lacks a statutory basis. Moreover, as neither party raises a challenge to the burden of proof applied in this case, unlike Justice Wecht, I would not address that issue. In contrast to the majority (and Justice Wecht’s augmented formulation), I see no need to create a new test given the well established test under the incidental powers doctrine, which both parties have agreed applies in this case. It has been an accepted principle from as early as the late 1800s that, in addition to the specific powers listed in a corporation’s charter, a corporation could engage in activities which were incidental to its main purpose. See Malone v. Lancaster Gas Light & Fuel Co., 182 Pa. 309, 37 A. 932, 933 (1987) (<HOLDING>); Citizens’ Elec., 99 A. at 467 (holding that
holding that gas line is not improvement holding provision in oil and gas lease authorizing lessor to use gas for agricultural purposes contained no geographical limitations holding that purchasing and supplying gasconsuming appliances was incidental to gas companys corporate purpose of manufacturing and supplying illuminating and heating gas holding that injury caused by criminal fleeing after stealing gas from gas station was not foreseeable result of stations policy of not requiring customers to prepay for gas holding plaintiffs were properly enjoined from using excessive amounts of gas not contemplated by the free gas clause in the lease