Delaware Valley Apartment House Owners' Ass'n v. Commonwealth, Department of Revenue

Opinion by

Judge Blatt,

This is an action within our original jurisdiction seeking a declaratory judgment on the constitutionality of Section 201 (m) of the Tax Reform Code of 19711 (Tax Code), 72 P.S. §7201(m). The petitioners are the Delaware Valley Apartment House Owners’ Association (association) and Hopkinson Associates, a limited partnership which owns and operates a residential apartment house in Philadelphia. The respondent is the Pennsylvania Department of Revenue. We are here concerned with the respondent’s preliminary objections which challenge the petitioners’ standing to bring this…