American Law Institute v. Commonwealth

OPINION BY

President Judge COLINS.

American Law Institute (ALI) petitions for review of the Board of Finance and Revenue’s (Board) order denying the renewal of its sales and use tax exemption1 as an institute of purely public charity.

*1090The facts as stipulated by the parties2 are as follows. ALI is a nonprofit corporation organized under the law of the District of Columbia with its principal place of business in Philadelphia. ALI’s charitable purposes are education and legal reform; more specifically, as stated in its certificate of incorporation, its goals are the clarification and simplification…