Overmont Corp. v. BD. TAX REVISION, ETC.

OPINION

LARSEN, Justice.

In 1963, the Philadelphia College of Osteopathic Medicine (herein referred to as PCOM), a tax exempt institution since its inception, decided to build a residence for senior citizens on a portion of its property. In order to expedite the paperwork inherent in applying for the financing needed for the project, PCOM, in 1966, created appellant Overmont Corporation, a separate non-profit corporation which would construct and operate the residence. On September 8, 1972, PCOM sold a portion of its property to appellant; this property was tax exempt during the period of time…