On July 17, the Commonwealth Court issued an opinion in Appeal of the City of Pittsburgh, which ruled that a purely public charity that acquired vacant lands in what it viewed as a furtherance of its mission, but without an intention to physically use or occupy the properties in either the short- or long-term, was not entitled to exemption from real estate taxes on those properties. The case places a narrow interpretation on certain portions of the language entitling such entities to real estate tax exemptions under the Pennsylvania Constitution and the General County Assessment Law.
The Pennsylvania Constitution provides that the Legislature may enact laws providing for the exemption from taxation of “institutions of purely public charity.” In the area of real estate taxes, such exemptions are limited to “only that portion of real property of such institution which is actually and regularly used for the purposes of the institution.”
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