Independent Oil and Gas Association v. Board of Assessment

OPINION

Chief Justice ZAPPALA.

In this case we granted allowance of appeal to determine whether the imposition of real estate, or ad valorem, taxes by Appellees on Appellants’ oil and gas interests is authorized by Pennsylvania law. Because we conclude that there is no authority for imposing a real estate tax on such interests, we reverse the order of the Commonwealth Court.1

Appellants own leasehold interests in oil and gas underlying tracts of land located in Fayette County.2 In June 1998, Appellee, the Board of Assessment Appeals of Fayette Coun*242ty, began to assess Appellants’ oil and gas…