PELLEGRINI, Judge.
MSG Associates, Inc. (Taxpayer) appeals a decision of the Court of Common Pleas of Lehigh County (trial court) holding that the Business Privilege Tax of the City of Allentown (Allentown or City) does not violate Article VIII, § 1 of the Pennsylvania Constitution by levying a different tax rate on services than it does on sales at either wholesale or retail or by allowing a
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