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WILSON PARTNERS v. BD. OF FINANCE & REV.

558 Pa. 462 (1999)

737 A.2d 1215

WILSON PARTNERS, L.P., Appellant, v. COMMONWEALTH of Pennsylvania, BOARD OF FINANCE AND REVENUE, Appellee. Academic Properties, Inc., Appellant, v. Commonwealth of Pennsylvania, Board of Finance and Revenue, Appellee.

Supreme Court of Pennsylvania.

Decided October 1, 1999.

Attorney(s) appearing for the Case

Joseph C. Bright, Kevin J. Moody, Wolf Block Schorr & Solis-Cohen, Philadelphia, for Wilson Partner, L.P.

Ronald H. Skubecz, Harrisburg, for Office of Atty. Gen.

Jill M. Strouss, Pa. Dept. of Revenue, Harrisburg, for PA Dept. of Revenue.

Before FLAHERTY, C.J., and ZAPPALA, CAPPY, CASTILLE, NIGRO, NEWMAN and SAYLOR, JJ.

OPINION

SAYLOR, Justice.

In these consolidated direct appeals, Appellants present constitutional challenges to the imposition of a tax at the one-percent rate established by the Pennsylvania Realty Transfer Tax Act within the context of a real estate transfer in which one party to the transaction is exempt.

In late 1993, Appellants Wilson Partners, L.P. and Academic Properties, Inc. (collectively, "Taxpayers") entered into separate, unrelated...

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