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OVERMONT CORP. v. BD. TAX REVISION, ETC.

479 Pa. 249 (1978)

388 A.2d 311

OVERMONT CORPORATION, Appellant, v. BOARD OF TAX REVISION OF the CITY OF PHILADELPHIA et al., Appellees.

Supreme Court of Pennsylvania.

Decided June 2, 1978.

Rehearing Denied July 20, 1978.

Attorney(s) appearing for the Case

Blank, Rome, Klaus & Comisky, Richard M. Rosenbleeth, Norman Perlberger, Philadelphia, for appellant.

James M. Penny, Jr., Asst. City Sol., Sheldon L. Albert, City Sol., Agostino Cammisa, Edgar R. Einhorn, Philadelphia, for appellees.

Before EAGEN, C.J., and O'BRIEN, ROBERTS, POMEROY, NIX, MANDERINO and LARSEN, JJ.

OPINION

LARSEN, Justice.

In 1963, the Philadelphia College of Osteopathic Medicine (herein referred to as PCOM), a tax exempt institution since its inception, decided to build a residence for senior citizens on a portion of its property. In order to expedite the paperwork inherent in applying for the financing needed for the project, PCOM, in 1966, created appellant Overmont Corporation, a separate non-profit corporation which would construct and operate...

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