Northeastern Pennsylvania Imaging Center v. Commonwealth

OPINION

Justice EAKIN.

In these consolidated appeals, the Commonwealth of Pennsylvania, Department of Revenue seeks review of the Commonwealth Court’s decisions holding appellees’ MRI1 and PET/CT2 Scan systems were not tangible personal property subject to sales tax under § 7202(a) of the Tax Reform Code of 1971, 72 P.S. § 7101 et seq., because they were part of real estate structures. We reverse.

The facts relevant to both appeals, as established by joint stipulation, are set forth individually below, along with the procedural history of each case.

Northeastern Pennsylvania Imaging Center v.…