RODGERS, Senior Judge.
Allegheny County (County) appeals from the May 26, 1998 order of the Court of Common Pleas of Allegheny County (trial court) that ordered the County to pay $2500.00 in counsel fees and $10,000.00 in punitive damages to John K. Whiteford. We reverse.
In January of 1991, Whiteford filed an equity action with the trial court seeking to determine the tax situs of his property, located at 3245 Miracle Drive.
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