Commonwealth v. City Realty Co.

Eagen, J.,

This is a case stated which by agreement was submitted to the writer for decision. The issue arises out of a sei. fa. sur lien proceeding involving corporate taxes instituted by the Commonwealth of Pennsylvania against the City Realty Company, defendant, and the State Capital Savings and Loan Association as terre tenant.

The facts disclose that on January 6, 1928, the City Realty Company conveyed its title to a piece of real estate in the City of Scranton to Harry Bernstein and William Greenfield. These individuals were the owners of substantially the entire stock issued by the…