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IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Sports & Exhibition Authority of Pittsburgh Allegheny County f/k/a Public Auditorium Authority of Pittsburgh and Allegheny County (Former owner Stadium Authority of the City of Pittsburgh from the decision of the Board of Property Assessment, Appeals Review and Registry as to property designated in the City of Pittsburgh, 22nd Ward, as Block & Lot 7-M-76

: : : : : : : : : : : : County of Allegheny, City of : Pittsburgh, School District of Pittsburgh : and Board of Property Assessment, : Appeals, Review & Registry : : Appeal of Sports and Exhibition : Authority of Allegheny County : Sports & Exhibition Authority of Pittsburgh Allegheny f/k/a Public Auditorium Authority of Pittsburgh and Allegheny County (Former Owner Stadium Authority of the City of Pittsburgh from the decision of the Board of Property, Assessment, Appeals Review and Registry as to property designated in the City of Pittsburgh, 22nd Ward, as Block & Lot 8-L-180 : : : : : : : : : : : County of Allegheny, City of : Pittsburgh, School District of Pittsburgh : and Board of Property, Assessment, : Appeal, Review & Registry : : Appeal of: The Sports & Exhibition : Authority of Allegheny County :

No. 190 C.D. 2001

No. 191 C.D. 2001

Sports & Exhibition Authority of Pittsburgh Allegheny f/k/a Public Auditorium Authority of Pittsburgh and Allegheny County (Former Owner Stadium Authority of the City of Pittsburgh from the decision of the Board of Property, Assessment, Appeals Review and Registry as to property designated in the City of Pittsburgh, 22nd Ward, as Block & Lot 8-L-40, 8-L-40A and 8-L-41

: : : : : : : : : : : : County of Allegheny, City of : Pittsburgh, School District of Pittsburgh : and Board of Property, Assessment, : Appeal, Review & Registry : : Appeal of: The Sports & Exhibition : Authority of Allegheny County : Sports & Exhibition Authority of Pittsburgh Allegheny County f/k/a Public Auditorium Authority of Pittsburgh and Allegheny County (Former Owner Stadium Authority of the City of Pittsburgh from the decision of the Board of Property, Assessment, Appeals Review and Registry as to property designated in the City of Pittsburgh, 22nd ward, as block & Lot 8-L-45, 8-L-47, 8-L-65, 8-L-68, 8-G-119 and 8-G-123 : : : : : : : : : : : : : County of Allegheny, City of : Pittsburgh, School District of Pittsburgh : and Board of Property, Assessment, : Appeals, Review and Registry : : Appeal of: Sports and Exhibition : Authority of Allegheny County :

No. 192 C.D. 2001

No. 193 C.D. 2001 Argued: October 10, 2001

BEFORE: HONORABLE DAN PELLEGRINI, Judge HONORABLE JIM FLAHERTY, Senior Judge HONORABLE SAMUEL L. RODGERS, Senior Judge OPINION BY SENIOR JUDGE FLAHERTY

FILED: November 20, 2001

The Sports & Exhibition Authority of Pittsburgh, Allegheny County (Authority) appeals from the order dated December 13, 2000 of the Court of Common Pleas of Allegheny County (trial court) which determined that the Sports Authority was not exempt from real estate taxes for the year 1999. Prior to December 31 of each year, the real property in Allegheny County is assessed for the following year, the results are correlated and are accessible by the municipalities, school districts and general public. January 1, 1999 is the official date of assessment (date of assessment) in the case sub judice. Certain properties (Properties) were purchased after the date of assessment by the Authority, an agency of the Commonwealth created under the provisions of the Public Auditorium Authorities Law (Law), Act of July 29, 1953, P.L. 1034, as amended, 53 P.S.

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Pennsylvania Law