SCH. DIST. OF PHILADELPHIA v. BD. OF REV.

No. 195 C.D. 2021-224 C.D. 2021, Nos. 226 C.D. 2021-229 C.D. 2021, Nos. 252 C.D. 2021-266 C.D. 2021 Nos. 268 C.D. 2021- 270 C.D. 2021, Nos. 272 C.D. 2021 No. 280 C.D. 2021, No. 285 C.D. 2021 No. 286 C.D. 2021 No. 283 C.D. 2021 No. 284 C.D. 2021 No. 226 C.D. 2021No. 268 C.D. 2021 No. 269 C.D. 2021 No. 272 C.D. 2021 No. 273 C.D. 2021 No. 282 C.D. 2021 No. 287 C.D. 2021 No. 288 C.D. 2021 No. 419 C.D. 2021.

303 A.3d 1150 (2023)

The SCHOOL DISTRICT OF PHILADELPHIA, Appellant v. BOARD OF REVISION OF TAXES, The City of Philadelphia, and Teva Pharmaceuticals USA. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and 401 Market Street a/k/a MREF 401 LP. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and 1500 Net Works Associates a/k/a Net Works Building. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and PR Chestnut Associates LP. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Hub Properties Trust now owned by Commonwealth of PA — SEPTA. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Two Logan Square Associates. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and OLS Office Partners LP. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Commerce Square Partners. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Maguire/Thomas PTNS Phila Plaza Phase II. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Cedar South Philadelphia. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and ARD Grant LP a/k/a The Court at Grant. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and 1760 Market Partners LP. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and SWP Real Estate LLC. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and BA Parkway Associates II a/k/a Embassy Suites. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Public Storage Properties XVIII. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and SPSP Corporation. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and 2400 Market VII LP a/k/a Marketplace Design Center. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and 4401 Walnut Holdings LLC. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and T C Pepper Building G P LLC a/k/a The Pepper Building. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Hill House Apartment Association a/k/a The Watermark. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and WWW Premier Holdings LLC a/k/a Winchester Walk. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Offices at Two Liberty PL. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and CRP-Grep Rushwood LP a/k/a Rushwood Apartments now owned by RSW Premier Holdings LLC. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Charter Court Holdings LL a/k/a Charter Court Apartments. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Cedar Quartermaster LLC. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and PR Northeast Limited Partnership a/k/a Northeast Tower Center. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Red Lion MZL LP. The School District of Philadelphia, Appellant. v. Board of Revision of Taxes, The City of Philadelphia, and Center City Chestnut LLC a/k/a Nineteen Thirty Chestnut. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and 777 South Broad Street AS. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and PR Walnut Associates LP. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Market Square Plaza I LLC. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Super Salvage, Inc. a/k/a CVS. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and 23rd Street Garage VII LP. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and 618 Market LP. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Brandywine Operating Partners LP a/k/a Bell Atlantic Tower. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Two Liberty Place LP. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Brandywine Operating Part. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Philadelphia-Harbison LP. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Treeco/Manor Limited Part. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Jar Chocolate Works LP. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and 1616-26 Walnut Street. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and PECO Energy Company. The School District of Philadelphia, Appellant, v. Board of Revision of Taxes, The City of Philadelphia, and Charter School Holdings LL a/k/a Charter Court Apartments. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Phila Liberty PLA E LP a/k/a/ Liberty One. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Panco CC Rittenhouse Row Rittenhouse Row Investors a/k/a American Patriots Bldg. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Post Rittenhouse Hill LP a/k/a Rittenhouse Hill Apartments. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Boulevard North Associate a/k/a Whitman Square. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Cedar Quartermaster II LL. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Boulevard North Associate LP a/k/a Whitman Square. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Delaware East Assoc LP a/k/a Columbus Commons. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Delaware East Assoc a/k/a Columbus Commons. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Center City Walnut LLC. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and Delaware East Associates a/k/a Columbus Commons. The School District of Philadelphia, Appellant v. Board of Revision of Taxes, The City of Philadelphia, and G2 S2 ASSPC LP a/k/a 1605 Sansom.

Commonwealth Court of Pennsylvania.

Decided October 6, 2023.

Reargument Denied November 30, 2023.


Attorney(s) appearing for the Case

Raymond P. Wendolowski , Kingston, for Designated Appellant. The School District of Philadelphia.

Glenn A. Weiner , Philadelphia; David Andrew Schneider , Princeton, NJ; Megan E. Moyer , Philadelphia; Jeffrey G. Wilhelm , Pittsburgh; and Kevin R. Boyle , Philadelphia; for Designated Appellees.

BEFORE: HONORABLE RENÉE COHN JUBELIRER, President Judge, HONORABLE ANNE E. COVEY, Judge, HONORABLE MARY HANNAH LEAVITT, Senior Judge.


The School District of Philadelphia (School District) has appealed an order of the Court of Common Pleas of Philadelphia County (trial court) that quashed the School District's appeal of 138 commercial property tax assessments.1 The School District argues that the trial court erred in...

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