OPINION BY JUDGE BARRY, December 28, 1988:
Appellant, Health Group Care Centers, Inc., is owned by Health Group, Inc., and is licensed by the Commonwealth to operate a long term nursing facility. In 1983 appellant purchased all of the assets of Negley House, Inc., owner of a nursing home in the City of Pittsburgh (City). In 1984 the Treasurer of the City mailed to appellant a notice of deficiency assessment of realty transfer tax for taxes due from the sale of the...
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