School District of Philadelphia v. Tax Review Board ex rel. Realen Gateway Development Associates, L.P.

LORD, Senior Judge.

This is an appeal from an order of the Court of Common Pleas of Philadelphia affirming a decision of the Philadelphia Tax Review Board (TRB, or board) in which it was found that Realen Gateway Development Associates (Realen) was not responsible for the Philadelphia Business Use and Occupancy Tax (U & O Tax) in connection with the operation of a public parking garage located at 15th and Vine Streets, Philadelphia. The U & O Tax is imposed by the School District of Philadelphia on the use and occupancy of certain real estate in the School District pur*907suant to the Act of…