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BANKERS SEC. CORP. v. PHILA. SCH. DIST

Superior Court of Pennsylvania.
Mar 18, 1959
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Taxation — General business tax — School District of Philadelphia — Petitioner engaged in various enterprises — Income from stock investments — "Business" — "Receipts" — Act of May 23, 1949, P.L. 1669, as amended.

On appeal from an assessment by the School District of Philadelphia for general business taxes under the Act of May 23, 1949, P.L. 1669, as amended, in which it appeared that petitioner operated a department store, four hotels, and had various other real estate holdings, from which it received a substantial gross income; that petitioner also owned securities, and that dividends on these securities, and profits from sales thereof, totaled a substantial sum; and that the court below, holding that petitioner was engaged in "business" and that the gross income from its investments constituted "receipts" within the meaning of the Act, concluded that petitioner's income from its investments was subject to the general business tax; it was Held that the judgment of the court below should be affirmed.

Argued June 12, 1958.

OPINION PER CURIAM, March 18, 1959:

Judgment affirmed on the opinion of the court below written by President Judge (now Justice) BOK and reported in 16 Pa. D. C.2d 248.