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PITTSBURGH APPEAL

439 Pa. 295 (1970)

Pittsburgh Appeal.

Supreme Court of Pennsylvania.

July 2, 1970.

Attorney(s) appearing for the Case

Frederick A. Boehm, First Assistant City Solicitor, with him Eugene B. Strassburger, III, Assistant City Solicitor, and Ralph Lynch, Jr., City Solicitor, for appellants.

Seymour J. Schafer, with him Markel, Markel, Levenson & Schafer, for appellees.

Before BELL, C.J., JONES, COHEN, EAGEN, O'BRIEN, ROBERTS and POMEROY, JJ.

OPINION BY MR. JUSTICE ROBERTS, July 2, 1970:

On December 28, 1968, the City of Pittsburgh enacted "The Institution and Service Privilege Tax Ordinance" which, in essence, sought to levy a six mills tax on the gross receipts1 of any institution2 engaging in any service3 in the City. Twenty-eight institutions performing health-related services...

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