Philadelphia Eagles Football Club, Inc. v. City of Philadelphia

CONCURRING AND DISSENTING OPINION

Justice CASTILLE.

I agree with the lead opinion that the Commonwealth Court correctly found that the Philadelphia Eagles Football Club’s media receipts resulting from the television broadcast of football games were subject to the City of Philadelphia’s Business Privilege Tax (BPT) because the media receipts constitute copyright royalties for the licensing of a property right. I respectfully disagree, however, with the lead opinion’s conclusion that the City’s failure to apportion those media receipts based upon the percentage of games the Football Club plays in…