Girard Trust Co. v. Philadelphia

Opinion by

Mr. Justice Horace Stern,

Stated as concisely as possible, the question is whether a mortgage which is merely security for the *501payment of accompanying bonds is subject to the personal property tax.

In 1924 the Penn Athletic Club conveyed its clubhouse at the northeast corner of 18th and Locust Streets, Philadelphia to one C. Benton Cooper, who thereupon executed to the Girard Trust Company, as Trustee, a mortgage indenture to secure an authorized issue of first mortgage bonds. The bonds were issued to various purchasers. It is not necessary for present purposes to recount in detail…