TAX REVIEW BD. OF PHILA. v. Heintz Inv. Co.

OPINION OF THE COURT

O’BRIEN, Justice.

This appeal arises from an order of the Commonwealth Court which reversed the order of the Court of Common Pleas of Philadelphia. We granted allocatur.

The narrow issue presented in this appeal is whether appellee, Heintz Investment Company, is “engaged in business” within the meaning of § 19-1001 et seq., of the *251Code of General Ordinances of the City of Philadelphia. In the Code, “business” is defined as follows:

“The carrying on or exercising for gain or profit within the City any trade, business, profession, vocation, or making sales to persons within the…