In the case of a “fictional” six-figure tax assessment, the justices of the Pennsylvania Supreme Court weighed arguments on the balance between the city of Philadelphia’s “scary practices” and a man’s failure to appeal the matter in a timely fashion.
Comments and questions from the justices during argument in City of Philadelphia v. Lerner, heard March 8 in Philadelphia, raised concerns about both sides of the case. The factual underpinnings of Nathan Lerner’s quest to evade a judgment of more than $280,000 were “rife with waiver,” according to Justice David N. Wecht. But the city’s “jeopardy assessment,” used to induce a taxpayer to cooperate, left Chief Justice Thomas G. Saylor bothered that the figure was “not tethered to reality.”
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