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LINCOLN PHILA. REALTY ASSOCIATES v. BD. OF REVISION OF TAXES OF CITY AND CTY. OF PHILADELPHIA

758 A.2d 1178 (2000)

LINCOLN PHILADELPHIA REALTY ASSOCIATES I, Appellee, v. The BOARD OF REVISION OF TAXES OF the CITY AND COUNTY OF PHILADELPHIA and the City of Philadelphia and the School District of Philadelphia, Appellants. Lincoln Philadelphia Realty Associates II, Appellee, v. The Board of Revision of Taxes of the City and County of Philadelphia and the City of Philadelphia and the School District of Philadelphia, Appellants. Nine Penn Center Associates, Appellee, v. The Board of Revision of Taxes of the City and County of Philadelphia and the City of Philadelphia and the School District of Philadelphia, Appellants. (Three Cases). Philadelphia Airport Business Center Limited Partnership, Appellee, v. The Board of Revision of Taxes of the City and County of Philadelphia and the City of Philadelphia and the School District of Philadelphia, Appellants. (Two Cases). Nine Penn Center Associates, Lincoln Philadelphia Realty Associates I, Lincoln Philadelphia Realty Associates II and Philadelphia Airport Business Center Limited Partnership, Appellees, v. The Board of Revision of Taxes of the City and County of Philadelphia and the City of Philadelphia and the School District of Philadelphia, Appellants.

Supreme Court of Pennsylvania.

Decided October 4, 2000.

Attorney(s) appearing for the Case

Mark A. Aronchick, Joseph A. Dworetzky, Michael Lieberman, Dara B. Less, Stephanie L. Franklin-Suber, Richard Feder, Philadelphia, for City of Philadelphia, the School Dist. of Philadelphia and the Bd. of Revision of Taxes.

Thomas A. Leonard, Michael P. Weinstein, Philadelphia, for Nine Penn Center.

Bruce Alan Herald, Exton, for Airport Business Center.

Before FLAHERTY, C.J., and ZAPPALA, CAPPY, CASTILLE, NIGRO and SAYLOR, JJ.

OPINION

SAYLOR, Justice.

This appeal concerns exemptions from local real estate taxation granted to Appellees, certain Philadelphia taxpayers, by Appellant, the Board of Revision of Taxes of the City and County of Philadelphia (the "Board").

I. Background

The history of this matter is complex, but highly relevant. In 1977, with the enactment of the Local Economic Revitalization Tax...

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