City of Philadelphia v. Tax Review Board of the City of Philadelphia Ex Rel. Aboyan

OPINION BY

Judge SMITH-RIBNER.

The City of Philadelphia (City) appeals from an order of the Court of Common Pleas of Philadelphia County that affirmed the order of the City’s Tax Review Board (Board) directing that the City apply the Black-Scholes Option-Pricing Formula (Black-Scholes formula) to the stock option income for each of the forty-five individual Appellees (Taxpayers) on their refund claims. 1 The City questions whether an amendment to a refund claim setting forth new facts not included in or relevant to the original claim was timely when it was asserted for the first time after…