Mikell v. Philadelphia School District

Opinion by

Mr. Justice Jones,

This is a suit to enjoin enforcement of an Act of Assembly (June 20, 1947, P. L. 733, 24 PS § 581.1-581.16) which imposed a personal property tax upon the residents of first class school districts “. . . for public school purposes . . .”. There are two such districts in the State, viz., Philadelphia and Pittsburgh. The plaintiff, a resident of the School District of Philadelphia, is a testamentary trustee and, as such, holds the title to intangible personal property which, by the terms of the Act, is expressly subjected to the tax. He challenges the validity of the…