Blue Cross Appeal

Opinion bt

Mr. Justice Jones,

In 1961, Blue Cross of Western Pennsylvania (Blue Cross), purchased certain realty in Pittsburgh for the purpose of erecting thereon its headquarters building. On April 27, 1961, Blue Cross filed a tax exemption application with the Board of Property *576Assessment, Appeals and Review of Allegheny County (Board), requesting the tax exemption of such realty under §8 of the “Nonprofit Hospital Plan Act”1 (Act) which provides: “Nonprofit corporations, subject to the provisions of this act, are hereby declared to be charitable and benevolent institutions, and all of their…