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ZILKA v. TAX REVIEW BD. PHILADELPHIA

No. 20 EAP 2022 No. 21 EAP 2022.

304 A.3d 1153 (2023)

Diane ZILKA, Appellant v. TAX REVIEW BOARD CITY OF PHILADELPHIA, Appellee Diane Zilka, Appellant v. Tax Review Board City of Philadelphia, Appellee.

Supreme Court of Pennsylvania.

Decided: November 22, 2023.

Attorney(s) appearing for the Case

Jennifer Weidler Karpchuk, Esq. , Stewart M. Weintraub, Esq. , Chamberlain, Hrdlicka, White, Williams & Aughtry, for Appellant.

Joan Carroll Arnold, Esq., Randy Lee Varner, Esq., Troutman Pepper Hamilton Sanders LLP, for Appellant Amicus Curiae American College of Tax Counsel.

Craig R. Gottlieb, Esq. , Laurice Ivonne Pollard Smith, Esq. , City of Philadelphia Law Department, for Appellee.

Alyssa M. Worden Amthor, Esq., Pennsylvania Department of Revenue, for Appellee Amicus Curiae Pennsylvania Department of Revenue.

TODD, C.J., DONOHUE, DOUGHERTY, WECHT, MUNDY, BROBSON, JJ.

OPINION

In this appeal by allowance, we consider whether the City of Philadelphia (the "City" or "Philadelphia") unconstitutionally discriminated against interstate commerce by subjecting a Philadelphia resident who worked exclusively out of state to its wage tax (the "Philadelphia Tax"), and...

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