Pittsburgh Appeal

Opinion by

Mr. Justice Roberts,

On December 28, 1968, the City of Pittsburgh enacted “The Institution and Service Privilege Tax Ordinance” which, in essence, sought to levy a six mills tax *297on the gross receipts1 of any institution2 engaging in any service3 in tbe City. Twenty-eight institutions performing health-related services then challenged the ordinance in the Court of Common Pleas of Allegheny County, as set forth in The Local Tax Enabling Act, Act of December 31, 1965, P.L. 1257, §6, 53 P.S. §6906 (Supp. 1970). In an effort to expedite the proceedings the parties agreed to select…