Willis v. City of Pittsburgh

Opinion by

Judge Crumlish, Jr.,

The City of Pittsburgh and the School District of Pittsburgh (Appellants) appeal the decision of the court of common pleas holding that A. F. Willis, d/b/a Penn Distributing Company (Appellee), is taxable as a wholesale vendor with respect to its sales to institutions pursuant to Appellants’ mercantile tax assessments.

As stated by the court below, the disputed transactions involve the “sales of novelty items including carnival prizes, bingo game cards, and party hats” to various nonprofit organizations.

The City’s tax is levied by Ordinance No. 595 of 1970, as…