Tyson v. Commonwealth

FRIEDMAN, Judge.

Richard L. and Audrey M. Tyson, husband and wife, (the Tysons) appeal from an order of the Board of Finance and Revenue (Board) which upheld the decision of the Department of Revenue Board of Appeals sustaining a realty transfer tax assessment against the Tysons in the amount of $106,-009.70, plus interest. The tax was assessed pursuant to section 1102-C of Article XI-C of the Tax Reform Code of 1971 (Realty Transfer Tax Act or Act)1 as a result of the recording of a deed on December 27, 1991.

*247The parties have stipulated to the following facts.2 In late 1989, Tim Tyson, the…