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CITY OF PHILA. v. BD. OF ASSESSMENT APPEALS

No. 102 MAP 2011

81 A.3d 24 (2013)

CITY OF PHILADELPHIA, Trustee under the will of Stephen Girard, Deceased, acting by the Board of Directors of City Trusts, Appellant v. CUMBERLAND COUNTY BOARD OF ASSESSMENT APPEALS, Appellee.

Supreme Court of Pennsylvania.

Decided October 30, 2013.

Attorney(s) appearing for the Case

Sarah Chadwick Cocke, Esq. , PFM Group, for Public Financial Management, Inc.

James G. Colins, Esq. , Stephen A. Cozen, Esq. , Sara Anderson Frey, Esq. , Cozen O'Connor, Philadelphia, Gary Dean Fry, Esq. , Archer & Greiner, P.C., Philadelphia, Christopher Anil Amar, Esq. , Charles B. Gibbons, Esq. , Pittsburgh, Jack Mentzer Stover, Esq. , Harrisburg, Buchanan Ingersoll & Rooney, P.C., Joseph T. Kelley Jr., Esq. , Kelley & Murphy, Howard A. Rosenthal, Esq. , for City of Philadelphia, Trustee Under the Will of S. Girard, Deceased, Acting by the Brd of Drectors.

Stephen Douglas Tiley, Esq. , Frey & Tiley, Carlisle, for Cumberland County Board of Assessment Appeals.

Robert L. Knupp, Esq. , Knupp Law Offices, LLC, Anthony T. McBeth, Esq. , Harrisburg, for County Commissioners Association of Pennsylvania.

BEFORE: CASTILLE, C.J., SAYLOR, EAKIN, BAER, TODD, McCAFFERY, ORIE MELVIN, JJ.

OPINION

Chief Justice CASTILLE.

The issue in this appeal is whether certain property (the "property") in Cumberland County, which is owned by the City of Philadelphia as trustee of the Stephen Girard Trust and leased by the Board of Directors of City Trusts (colloquially and hereinafter "the Board of City Trusts" and, where the context is clear, "the Board") to the Pennsylvania Office of Attorney General ("OAG"), is subject to local real estate taxation...

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