American Law Institute v. Commonwealth

Dissenting Opinion by

Senior Judge KELLEY.

I respectfully dissent. I believe the majority’s holding, that the American Law Institute (ALI) is entitled to a renewal of its sales and use tax exemption as an institute of purely public charity, erodes the meaning of the term “charity.”

In support of its holding, the majority primarily relies upon American Society for Testing Materials v. Board of Revision of Taxes, 423 Pa. 530, 225 A.2d 557 (1967) (ASTM), wherein the Supreme Court upheld the Society’s exemption as a purely public charity over the City of Philadelphia’s objection that its principal…