City of Pittsburgh v. Ivy School of Professional Art, Inc.

Opinion by

President Judge Bowman,

Ivy School of Professional Art, Inc. (Ivy) is a corporation organized under Pennsylvania law as a corporation for profit engaged in the business of operating a school for the teaching of art, photography and related subjects.

Prom 1970 through 1975, Ivy paid taxes to the City, of Pittsburgh (City) on its gross receipts, excluding-*408therefrom State and Federal funds attributable to a variety of aid programs, which funds were received for and credited to the accounts of individual students. The City contends that for those years Ivy was liable for the City’s…