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SHERATON CORP. v. COMMONWEALTH

No. 471.

47 Pa. D. & C. 2d 371 (1969)

Sheraton Corporation of America v. Commonwealth

Common Pleas Court of Dauphin County, Pennsylvania.

May 19, 1969.

Attorney(s) appearing for the Case

Tice F. Ryan, Jr., Ryan, Newman, Greer & Goldring, for appellant.

Eugene J. Anastasio, Deputy Attorney General; William C. Sennett, Attorney General, for Commonwealth.

LIPSITT, J., May 19, 1969.

In this appeal from a determination of the Board of Finance and Revenue of the Commonwealth of Pennsylvania, the Sheraton Corporation of America (hereinafter called "Sheraton") seeks a refund of a realty transfer tax in the amount of $11,961.40. The key legal issue enmeshed in a succession of business and realty transactions is whether Sheraton is entitled to an exclusion from tax liability by classifying it as a purchase money mortgagee...

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