Pennsylvania Co. for Insurances on Lives & Granting Annuities v. Philadelphia

Opinion by

Mr. Justice Allen M. Steabne,

This is an appeal from an Order restraining the Defendant City from assessing against the Plaintiff an income tax upon the profits accruing from its operation of certain business properties, as Trustee for individual and sundry trusts.

Section 2(c) of the Philadelphia Income Tax Ordinance, approved December 13, 1939, imposes a tax of one and one-half per centum, subsequently reduced to one per centum, upon “the net profits earned after January 1, 1939, of businesses, professions or other activities conducted by . . . residents.” It is further provided :

“Th…