City of Pittsburgh v. International Business Machines Corp.

Opinion by

Judge Crumlish, Jr.,

The City of Pittsburgh and Joseph L. Cosetti, Treasurer of the City of Pittsburgh (Appellants/City) appeal a decision of the Court of Common Pleas which held that the International Business Machines Corporation (IBM) is exempt from the City’s business privilege tax on rental receipts generated from the lease of IBM manufactured equipment within the City.

*54We affirm.

By authority of The Local Tax Enabling Act, Act of December 31, 1965, P.L. 1257, as amended, 53 P.S. §6901 et seq. (Act 511), the City enacted Ordinance No. 675 (Ordinance) imposing a tax on the…