Principal Life Insurance v. City of Philadelphia Tax Review Board

OPINION BY

Judge LEAVITT.

Principal Life Insurance Company (Principal) appeals from an order of the Court of Common Pleas of the County of Philadelphia (trial court) that required Principal to pay a business privilege tax (BPT) on rental income it received from certain commercial properties Principal owned in the City of Philadelphia (City). In doing so, the trial court affirmed a decision of the Philadelphia Tax Review Board (Board) and rejected Principal’s claim that the revenue in question was non-taxable because it was derived from the “business of an insurance company.”1 We affirm in part…