Wilson Partners v. BD. OF FINANCE & REV.

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 agreements with the Federal Deposit Insurance Corporation, as receiver for a failed bank, for the purchase of various parcels of property located in…