OPINION BY JUDGE CRAIG, May 24, 1985:
Pier 30 Associates appeals an order of Judge GELFAND of the Court of Common Pleas of Philadelphia County which upheld the Philadelphia School District's denial of Pier 30's appeal from the imposition of local use and occupancy tax on tennis courts constructed and operated by Pier 30 on property owned by the city, leased by the Philadelphia Port Corporation (a municipal agency), and sublet to Pier 30 Associates.
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