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FREEDMAN et al. v. PHILA. TAX REV. BD.

212 Pa.Super. 442 (1968)

Freedman et al., Appellants, v. Philadelphia Tax Review Board.

Superior Court of Pennsylvania.

June 13, 1968.

Attorney(s) appearing for the Case

Marvin J. Levin, with him Freedman, Borowsky and Lorry, for appellants.

Levy Anderson, First Deputy City Solicitor, with him Allan Gordon, Assistant City Solicitor, and Edward G. Bauer, Jr., City Solicitor, for appellee.

Before WRIGHT, P.J., WATKINS, MONTGOMERY, JACOBS, HOFFMAN, SPAULDING, and HANNUM, JJ.

OPINION BY HOFFMAN, J., June 13, 1968:

The sole issue in this case is whether a taxpayer's income, earned as a limited partner, is subject to the Philadelphia Net Profits Tax. Philadelphia General Code of Ordinances § 19-501 et seq.

By agreement dated July 15, 1952, a partnership known as Flandel Enterprises was formed for the purpose of owning and operating interests in realty and personalty. The partnership agreement provided for the formation of a...

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