Commonwealth v. Erie Metropolitan Transit Authority

Opinion by

Mr. Justice Pomeroy,

The question presented by this appeal is whether or not a municipal transportation authority organized and Existing under the Municipality Authorities Act of 19451 (the Authorities Act) is subject to tax liability *347under The Liquid Fuels Tax Act (the Fuels Tax Act).2 Appellant, the Erie Metropolitan Transit Authority (ETA), formed by the City of Erie and Erie County under the Authorities Act, asserts that it is not so subject; the Commonwealth, appellee, claims that it is, and the court below, after a nonjury trial, agreed.3

The corporate purposes of ETA as set…