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CITY OF PORTSMOUTH v. CITIZENS TRUST CO.

Record No. 741178.

222 S.E.2d 532 (1976)

CITY OF PORTSMOUTH v. CITIZENS TRUST COMPANY, Trustee, etc., et al.

Supreme Court of Virginia.

March 5, 1976.

Attorney(s) appearing for the Case

Gordon B. Tayloe, Jr., Norfolk, for plaintiff in error.

J. Stanley Livesay, Jr., Portsmouth (Schlitz, Levy & Livesay, Ltd., Portsmouth, on brief), for defendants in error.

Howard E. Gordon, Norfolk (Robert C. Nusbaum, Hofheimer, Nusbaum & McPhaul, Norfolk, on brief), for Churchland Square Apartments, amicus curiae.

Before CARRICO, HARRISON, COCHRAN, HARMAN, POFF and COMPTON, JJ.

COCHRAN, Justice.

This appeal presents for our determination the question of the validity of two local ordinances levying license taxes on those engaged in the business of renting residential property.

On June 22, 1971, City Council of the City of Portsmouth adopted for the license tax year beginning May 1, 1972, and for subsequent tax years, Ordinance No. 1971-52,1 in which the definition of those required to pay the tax paralleled...

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