OPINION BY JUDGE MENCER, December 21, 1976:
The City of Pittsburgh (City) has appealed from an order of the Court of Common Pleas of Allegheny County which granted a tax exemption to the Homewood-Brushton Citizens Renewal Council (Council). The Council successfully sought to have the gross receipts of a roller skating rink exempted from the Pittsburgh Institution and Service Privilege Tax (Tax). This tax is in the nature of an excise tax imposed on nonprofit institutions...
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