Allebach v. DEPT. OF FINANCE AND REVENUE

OPINION OF THE COURT

CAPPY, Justice.

This is a direct appeal 1 from the order of the Commonwealth Court reversing the order of the Board of Finance and Revenue. For the reasons that follow, we now affirm.

The parties to this matter stipulated to the following facts. The Allebachs, who are Appellees in the matter before this court, were the owners of a 63-acre tract of land in the Borough of Trappe, Montgomery County. On April 16, 1987, the Allebachs entered into an agreement of sale (“1987 Agreement”) with John Ward (‘Ward”), trading as L & W Associates, whereby Ward and his nominees and…