uniformity clause in Pennsylvania

2026Assessment, Appeals & Review of Allegheny Cnty., . . . 209 A.2d 389 ([Pa.] 1965)); see also Clifton[ v. Allegheny Cnty., 969 A.2d 1197, 1212 (Pa. 2009)] (“[T]his Court has consistently interpreted the uniformity requirement of the Pennsylvania Constitution as requiring all real estate to be treated as a single class entitled to uniform treatment.”).

2026Thus, “all real estate in a taxing district is constitutionally entitled to uniform treatment.” Id., citing Clifton, 969 A.2d at 1212 (“this Court has consistently interpreted the uniformity requirement of the Pennsylvania Constitution as requiring all real estate to be treated as a single class entitled to uniform treatment”).

2026Assessment, Appeals & Review of Allegheny Cty., 209 A.2d 397, 401 (Pa. 1965) (affirming the uniformity principle that “a taxpayer should pay no more or no less than his proportionate share of the cost of government”).

2026Assessment, Appeals & Review of Allegheny Cty., 209 A.2d 397, 402 (Pa. 1965) (“the uniformity requirement of the Constitution of Pennsylvania has been construed to require that all real estate is a class which is entitled to uniform treatment”); McKnight Shopping Ctr., Inc. v. Bd. of Prop.

2025(Cohn Jubelirer, P.J., dissenting). 22 Although we granted review of the Uniformity Clause issue, we declined to take up the issue of whether the lower courts erred in striking the entire ordinance rather than selectively severing it. 23 Commonwealth v. Overholt & Co., 200 A. 849, 853 (Pa. 1938). 24 Clifton v. Allegheny Cty., 969 A.2d 1197, 1211 (Pa. 2009). 25 Aldine Apartments v. Commonwealth, 426 A.2d 1118, 1121 (Pa. 1981); Leonard v. Thornburgh, 489 A.2d 1349, 1352 (Pa. 1985). 26 Columbia Gas Corp. v. Commonwealth, 360 A.2d 592, 595 (Pa. 1976). 27 Aldine Apartments, 426 A.2d at 1121-22 . [J

2025Danyluk, in other 45 Id. at 610. 46 Id. at 610-11. 47 Leonard, 489 A.2d at 1352 (describing Danyluk as holding that a capitation tax on non-residents is “unauthorized and invalid, with dictum indicating that an occupation tax levied only against non-residents would violate constitutional uniformity standards”); accord Brief for City of Pittsburgh at 27 (“Any reference in Danyluk to the residency distinction violating the Uniformity Clause was dicta[.]”). 48 We note that the only issue raised in Danyluk was a Uniformity Clause challenge, and the Danyluk Court’s bottom-line conclusion was that “

2024Albarano v. Bd. of Assessment & Revision of Taxes & Appeals, Lycoming Cnty., 494 A.2d 47, 49 (Pa. Cmwlth. 1985) (explaining that the taxpayer must prove “that a lower ratio of assessment to actual value has been applied to comparable properties”).10 9 Accord Valley Forge, 163 A.3d at 973 ; Clifton, 969 A.2d at 1201, 1206-07 (noting the taxpayers’ uniformity challenge based on their overassessed properties); Beattie v. Allegheny Cnty., 907 A.2d 519, 520 (Pa. 2006); Bradford Twp.

2006See Beattie, ___ Pa. at ___, 907 A.2d at 523 (citing Fisher Controls Co. v. Commonwealth, 476 Pa. 119, 127 , 381 A.2d 1253, 1257 (1977)). [11] Accord GOODMAN, ASSESSMENT LAW & PROCEDURE at 255 (criticizing the Commonwealth Court's failure in Hromisin to cognize the common law scheme for raising a uniformity challenge, and stating: "It was thought that when the court in Fosko spelled out the rules and procedures for uniformity challenges in 1994, a workable system was established for these cases.

2026Assessment, Appeals & Review of Allegheny Cnty., . . . 209 A.2d 389 ([Pa.] 1965)); see also Clifton[ v. Allegheny Cnty., 969 A.2d 1197, 1212 (Pa. 2009)] (“[T]his Court has consistently interpreted the uniformity requirement of the Pennsylvania Constitution as requiring all real estate to be treated as a single class entitled to uniform treatment.”).

2024But in the context of “determining the market value of a specific property,” the term “comparable properties” “means properties of a similar nature which have been recently sold.” Id. at 393 ; accord Downingtown, 913 A.2d at 199 (emphasizing that “all properties in the relevant taxing district are comparable properties for purposes of calculating the appropriate ratio of assessed value to market value (as all real estate is a class which is entitled to uniform treatment)” but that “in the context of a uniformity challenge, the parties and the trial court may rely upon evidence concerning the a

2026See, e.g., Valley Forge, 163 A.3d at 977 ; Clifton, 969 A.2d at 1212 (“[T]his Court has consistently interpreted the uniformity requirement of the Pennsylvania Constitution as requiring all real estate to be treated as a single class entitled to uniform treatment”); id. at 1213 (“judicial review of uniformity challenges to a statutory scheme of property taxation often needs only to focus on . . . a rule is impractical and finds no support in the Uniformity Clause’s text or history.” Majority Opinion at 16.

2026See, e.g., Valley Forge, 163 A.3d at 977 ; Clifton, 969 A.2d at 1212 (“[T]his Court has consistently interpreted the uniformity requirement of the Pennsylvania Constitution as requiring all real estate to be treated as a single class entitled to uniform treatment”); id. at 1213 (“judicial review of uniformity challenges to a statutory scheme of property taxation often needs only to focus on . . . a rule is impractical and finds no support in the Uniformity Clause’s text or history.” Majority Opinion at 16.

2026See also GM Berkshire, 290 A.3d at 250 (Mundy, J., OISA) (“If pronounced inequalities become pervasive, relief compelling a countywide reassessment may be available.”); Mount Airy #1, 154 A.3d at 277 (we may not “overlook the patently discriminatory effect of a particular tax merely because the General Assembly employed a formula that, at first blush, does not resemble a traditional variable-rate tax”); Beattie v. Allegheny Cty., 907 A.2d 519, 523-24 (Pa. 2006) (in case about administrative exhaustion, affirming Commonwealth Court decision that if “a discriminatory effect [against lower value

2026See also GM Berkshire, 290 A.3d at 250 (Mundy, J., OISA) (“If pronounced inequalities become pervasive, relief compelling a countywide reassessment may be available.”); Mount Airy #1, 154 A.3d at 277 (we may not “overlook the patently discriminatory effect of a particular tax merely because the General Assembly employed a formula that, at first blush, does not resemble a traditional variable-rate tax”); Beattie v. Allegheny Cty., 907 A.2d 519, 523-24 (Pa. 2006) (in case about administrative exhaustion, affirming Commonwealth Court decision that if “a discriminatory effect [against lower value

2024The statutory cap at issue allowed corporations in 2014 to carry forward net operating losses from prior years, but only up to the greater of 21 181 A. 598 (Pa. 1935). 22 184 A. 37 (Pa. 1936). 23 27 A.2d 62 (Pa. 1942). 24 196 A.2d 664 (Pa. 1964). 25 279 A.2d 53 (Pa. 1971). 26 154 A.3d 268 (Pa. 2016). 27 Gen.

2024The statutory cap at issue allowed corporations in 2014 to carry forward net operating losses from prior years, but only up to the greater of 21 181 A. 598 (Pa. 1935). 22 184 A. 37 (Pa. 1936). 23 27 A.2d 62 (Pa. 1942). 24 196 A.2d 664 (Pa. 1964). 25 279 A.2d 53 (Pa. 1971). 26 154 A.3d 268 (Pa. 2016). 27 Gen.

2009This means that all real estate is a constitutionally designated class entitled to uniform treatment and the ratio of assessed value to market value adopted by the taxing authority must be applied equally and uniformly to all real estate within the taxing authority’s jurisdiction. 652 A.2d at 1314 (emphasis added); see also Keebler Co. v. Bd. of Revision of Taxes of Phila., 496 Pa. 140 , 436 A.2d 583, 584 (1981) (“[A]ll real estate is a class which is entitled to uniform treatment.”). 22 Previously, this Court had suggested an absolutist approach when describing the uniformity requirement, hol

2009This means that all real estate is a constitutionally designated class entitled to uniform treatment and the ratio of assessed value to market value adopted by the taxing authority must be applied equally and uniformly to all real estate within the taxing authority’s jurisdiction. 652 A.2d at 1314 (emphasis added); see also Keebler Co. v. Bd. of Revision of Taxes of Phila., 496 Pa. 140 , 436 A.2d 583, 584 (1981) (“[A]ll real estate is a class which is entitled to uniform treatment.”). 22 Previously, this Court had suggested an absolutist approach when describing the uniformity requirement, hol

2025(Cohn Jubelirer, P.J., dissenting). 22 Although we granted review of the Uniformity Clause issue, we declined to take up the issue of whether the lower courts erred in striking the entire ordinance rather than selectively severing it. 23 Commonwealth v. Overholt & Co., 200 A. 849, 853 (Pa. 1938). 24 Clifton v. Allegheny Cty., 969 A.2d 1197, 1211 (Pa. 2009). 25 Aldine Apartments v. Commonwealth, 426 A.2d 1118, 1121 (Pa. 1981); Leonard v. Thornburgh, 489 A.2d 1349, 1352 (Pa. 1985). 26 Columbia Gas Corp. v. Commonwealth, 360 A.2d 592, 595 (Pa. 1976). 27 Aldine Apartments, 426 A.2d at 1121-22 . [J

2025(Cohn Jubelirer, P.J., dissenting). 22 Although we granted review of the Uniformity Clause issue, we declined to take up the issue of whether the lower courts erred in striking the entire ordinance rather than selectively severing it. 23 Commonwealth v. Overholt & Co., 200 A. 849, 853 (Pa. 1938). 24 Clifton v. Allegheny Cty., 969 A.2d 1197, 1211 (Pa. 2009). 25 Aldine Apartments v. Commonwealth, 426 A.2d 1118, 1121 (Pa. 1981); Leonard v. Thornburgh, 489 A.2d 1349, 1352 (Pa. 1985). 26 Columbia Gas Corp. v. Commonwealth, 360 A.2d 592, 595 (Pa. 1976). 27 Aldine Apartments, 426 A.2d at 1121-22 . [J

2024In Warner Brothers, for example, we rejected a Uniformity Clause challenge to a flat-dollar cap on deductions from corporate income. 45 Although this Court did not fully explain why the corporate deduction in Warner Brothers satisfied the Uniformity Clause while the individual exemptions in Cope’s Estate and Kelley did not, we would go on to clarify many years later that analogies between individual income taxes and corporate income taxes are “unpersuasive” because corporations “are artificial legal entities created with the permission of the state for the purpose of maximizing profits for sha

2024In Warner Brothers, for example, we rejected a Uniformity Clause challenge to a flat-dollar cap on deductions from corporate income. 45 Although this Court did not fully explain why the corporate deduction in Warner Brothers satisfied the Uniformity Clause while the individual exemptions in Cope’s Estate and Kelley did not, we would go on to clarify many years later that analogies between individual income taxes and corporate income taxes are “unpersuasive” because corporations “are artificial legal entities created with the permission of the state for the purpose of maximizing profits for sha

2019See, e.g., Nextel, 171 A.3d at 698 (“In determining whether this statute violates the Uniformity Clause, we do not look at its language in a vacuum[.]”); Shelly Funeral Home, 57 A.3d at 1141 (“When assessing the validity of tax legislation, the nomenclature employed by the General Assembly is not necessarily dispositive, as our analysis considers how the tax operates in practice.”); Clifton, 969 A.2d at 1211 (“When a method or formula for computing a tax will, in its operation or effect, produce arbitrary, unjust, or unreasonably discriminatory results, the uniformity requirement is violated.”

2019See , e.g. , Nextel , 171 A.3d at 698 ("In determining whether this statute violates the Uniformity Clause, we do not look at its language in a vacuum[.]"); Shelly Funeral Home , 57 A.3d at 1141 ("When assessing the validity of tax legislation, the nomenclature employed by the General Assembly is not necessarily dispositive, as our analysis considers how the tax operates in practice."); Clifton , 969 A.2d at 1211 ("When a method or formula for computing a tax will, in its operation or effect, produce arbitrary, unjust, or unreasonably discriminatory results, the uniformity requirement is viola

2003In Hromisin v. Board of Assessment Appeals of Luzerne County, 719 A.2d 815, 819 (Pa.Cmwlth.1998), allocatur denied, 558 Pa. 634 , 737 A.2d 1227 (1999), this Court reviewed the 1982 amendments to the Law and noted: Aside from the fact that the conclusions reached by taxpayers' expert here do not support a uniformity challenge, we must comment briefly upon the nature of the methodology employed.

2003In Hromisin v. Board of Assessment Appeals of Luzerne County, 719 A.2d 815, 819 (Pa.Cmwlth.1998), allocatur denied, 558 Pa. 634 , 737 A.2d 1227 (1999), this Court reviewed the 1982 amendments to the Law and noted: Aside from the fact that the conclusions reached by taxpayers’ expert here do not support a uniformity challenge, we must comment briefly upon the nature of the methodology employed.

2006See Beattie, ___ Pa. at ___, 907 A.2d at 523 (citing Fisher Controls Co. v. Commonwealth, 476 Pa. 119, 127 , 381 A.2d 1253, 1257 (1977)). [11] Accord GOODMAN, ASSESSMENT LAW & PROCEDURE at 255 (criticizing the Commonwealth Court's failure in Hromisin to cognize the common law scheme for raising a uniformity challenge, and stating: "It was thought that when the court in Fosko spelled out the rules and procedures for uniformity challenges in 1994, a workable system was established for these cases.

2006See Beattie, ___ Pa. at ___, 907 A.2d at 523 (citing Fisher Controls Co. v. Commonwealth, 476 Pa. 119, 127 , 381 A.2d 1253, 1257 (1977)). [11] Accord GOODMAN, ASSESSMENT LAW & PROCEDURE at 255 (criticizing the Commonwealth Court's failure in Hromisin to cognize the common law scheme for raising a uniformity challenge, and stating: "It was thought that when the court in Fosko spelled out the rules and procedures for uniformity challenges in 1994, a workable system was established for these cases.

2024But in the context of “determining the market value of a specific property,” the term “comparable properties” “means properties of a similar nature which have been recently sold.” Id. at 393 ; accord Downingtown, 913 A.2d at 199 (emphasizing that “all properties in the relevant taxing district are comparable properties for purposes of calculating the appropriate ratio of assessed value to market value (as all real estate is a class which is entitled to uniform treatment)” but that “in the context of a uniformity challenge, the parties and the trial court may rely upon evidence concerning the a

2012In Downingtown, supra, the Supreme Court reversed and remanded the case to the trial court for consideration of the adequacy of the owner’s uniformity challenge under Deitch Co. v. Bd. of Property Assessment [ 417 Pa. 213 ], 209 A.2d 397 (Pa.1965) and its progeny.

1994Id. 28 Pa.Cmwlth. at 436-37 , 368 A.2d at 912-13 (citations omitted.) The decision of the Commonwealth Court was affirmed sub nom. in Commonwealth v. Westinghouse Electric Corp., 478 Pa. 164 , 386 A.2d 491 , appeal dismissed, 439 U.S. 805 , 99 S.Ct. 61 , 58 L.Ed.2d 97 (1978), where the court said: [T]his Court has held that a state tax is not violative of the uniformity clause if the tax ‘applies to all corporations with which the Commonwealth has power constitutionally to deal---- Where the (state tax) base is the same and the rate unvarying, there is no lack of uniformity.’ ...

1994Id. 28 Pa.Cmwlth. at 436-37 , 368 A.2d at 912-13 (citations omitted.) The decision of the Commonwealth Court was affirmed sub nom. in Commonwealth v. Westinghouse Electric Corp., 478 Pa. 164 , 386 A.2d 491 , appeal dismissed, 439 U.S. 805 , 99 S.Ct. 61 , 58 L.Ed.2d 97 (1978), where the court said: [T]his Court has held that a state tax is not violative of the uniformity clause if the tax ‘applies to all corporations with which the Commonwealth has power constitutionally to deal---- Where the (state tax) base is the same and the rate unvarying, there is no lack of uniformity.’ ...

2021The Court observed, however, that, in the context of a uniformity challenge, the parties and the trial court may rely upon evidence concerning the assessment-to- value ratio of similar properties, as was done in Brooks PAM - 2 Building, see Deitch, 209 A.2d at 402-03 ; see also Brooks Building, 137 A.2d at 275 (stating that “the tax must be applied with uniformity upon similar kinds of business or property”), because such “similar properties” evidence, while not comprehensive, is nonetheless relevant to the uniformity analysis; further, it would be a practical impossibility to require the taxp

2021The Court observed, however, that, in the context of a uniformity challenge, the parties and the trial court may rely upon evidence concerning the assessment-to- value ratio of similar properties, as was done in Brooks PAM - 2 Building, see Deitch, 209 A.2d at 402-03 ; see also Brooks Building, 137 A.2d at 275 (stating that “the tax must be applied with uniformity upon similar kinds of business or property”), because such “similar properties” evidence, while not comprehensive, is nonetheless relevant to the uniformity analysis; further, it would be a practical impossibility to require the taxp

2009This means that all real estate is a constitutionally designated class entitled to uniform treatment and the ratio of assessed value to market value adopted by the taxing authority must be applied equally and uniformly to all real estate within the taxing authority’s jurisdiction. 652 A.2d at 1314 (emphasis added); see also Keebler Co. v. Bd. of Revision of Taxes of Phila., 496 Pa. 140 , 436 A.2d 583, 584 (1981) (“[A]ll real estate is a class which is entitled to uniform treatment.”). 22 Previously, this Court had suggested an absolutist approach when describing the uniformity requirement, hol

2009This means that all real estate is a constitutionally designated class entitled to uniform treatment and the ratio of assessed value to market value adopted by the taxing authority must be applied equally and uniformly to all real estate within the taxing authority’s jurisdiction. 652 A.2d at 1314 (emphasis added); see also Keebler Co. v. Bd. of Revision of Taxes of Phila., 496 Pa. 140 , 436 A.2d 583, 584 (1981) (“[A]ll real estate is a class which is entitled to uniform treatment.”). 22 Previously, this Court had suggested an absolutist approach when describing the uniformity requirement, hol

2025(Cohn Jubelirer, P.J., dissenting). 22 Although we granted review of the Uniformity Clause issue, we declined to take up the issue of whether the lower courts erred in striking the entire ordinance rather than selectively severing it. 23 Commonwealth v. Overholt & Co., 200 A. 849, 853 (Pa. 1938). 24 Clifton v. Allegheny Cty., 969 A.2d 1197, 1211 (Pa. 2009). 25 Aldine Apartments v. Commonwealth, 426 A.2d 1118, 1121 (Pa. 1981); Leonard v. Thornburgh, 489 A.2d 1349, 1352 (Pa. 1985). 26 Columbia Gas Corp. v. Commonwealth, 360 A.2d 592, 595 (Pa. 1976). 27 Aldine Apartments, 426 A.2d at 1121-22 . [J

1994Furthermore, “under the equal protection clause, and under the uniformity clause, absolute equality and perfect uniformity in taxation are not required.” City of Pittsburgh v. Commonwealth, 522 Pa. 20, 24-25 , 559 A.2d 513, 515 (1989) quoting Columbia Gas Corp. v. Commonwealth, 468 Pa. 145, 151 , 360 A.2d 592, 595 (1976).

2017See Cope’s Estate, 43 A. at 81 (“A pretended classification, that is based solely on a difference in quantity of precisely the same kind of property, is necessarily unjust, arbitrary, and illegal.”); Kelley, 181 A. at 602 (“[A] tax which is imposed at different rates upon the same kind of property, solely on the basis of the quantity involved, offends the uniformity clause.”); Mt.

2017See Cope’s Estate, 43 A. at 81 (“A pretended classification, that is based solely on a difference in quantity of precisely the same kind of property, is necessarily unjust, arbitrary, and illegal.”); Kelley, 181 A. at 602 (“[A] tax which .is imposed at different rates upon the same kind of property, solely on the basis of the quantity involved, offends the uniformity clause.”); Mt.

2004In Appeal of Armco, Inc., 100 Pa. Cmwlth. 452, 515 A.2d 326, 329 (1986), petitions for allowance of appeal denied, 516 Pa. 643 , 533 A.2d 714 (1987), this Court stated: “In tax matters, alleged violations of the equal protection clause and the uniformity clause are analyzed in the same manner; a taxpayer alleging that the administration of a tax violates its rights to be taxed uniformly with others of its class must demonstrate deliberate, purposeful discrimination in the application of the tax before constitutional safeguards are violated.” Although the use of the words “deliberate” and “purp

2004In Appeal of Armco, 515 A.2d at 326 , this Court held that an assessment satisfies the requirements of the uniformity clause “where the taxing authority assesses all property at the same percentage of its actual value; application of such a uniform ratio assures each taxpayer will be held responsible for its- pro rata share of the burden of local government.” Some of Taxpayers’ initial averments show that certified appraisals and sales of similar homes were much lower than the County-determined fair market value. 4 Taxpayers claim that the 2001 countywide reassessment was flawed because it fai

2026See id. at 47-49, citing, e.g., Danson v. Casey, 399 A.2d 360, 366-67 (Pa. 1979) (observing the framers of the 1874 Constitution considered and rejected adding a uniformity requirement to the Education Clause, thereby “endors[ing] the concept of local control to meet diverse local needs”); William Penn Sch.

2017See Danson v. Casey, 484 Pa. 415 , 399 A.2d 360, 366-67 (1979) (noting that the framers of the 1874 Constitution considered and rejected adding a uniformity requirement to the Education Clause, thereby “endors[ing] the concept of local control to meet diverse local needs”).

2024In Warner Brothers, for example, we rejected a Uniformity Clause challenge to a flat-dollar cap on deductions from corporate income. 45 Although this Court did not fully explain why the corporate deduction in Warner Brothers satisfied the Uniformity Clause while the individual exemptions in Cope’s Estate and Kelley did not, we would go on to clarify many years later that analogies between individual income taxes and corporate income taxes are “unpersuasive” because corporations “are artificial legal entities created with the permission of the state for the purpose of maximizing profits for sha

2024In Warner Brothers, for example, we rejected a Uniformity Clause challenge to a flat-dollar cap on deductions from corporate income. 45 Although this Court did not fully explain why the corporate deduction in Warner Brothers satisfied the Uniformity Clause while the individual exemptions in Cope’s Estate and Kelley did not, we would go on to clarify many years later that analogies between individual income taxes and corporate income taxes are “unpersuasive” because corporations “are artificial legal entities created with the permission of the state for the purpose of maximizing profits for sha

1994Id. 28 Pa.Cmwlth. at 436-37 , 368 A.2d at 912-13 (citations omitted.) The decision of the Commonwealth Court was affirmed sub nom. in Commonwealth v. Westinghouse Electric Corp., 478 Pa. 164 , 386 A.2d 491 , appeal dismissed, 439 U.S. 805 , 99 S.Ct. 61 , 58 L.Ed.2d 97 (1978), where the court said: [T]his Court has held that a state tax is not violative of the uniformity clause if the tax ‘applies to all corporations with which the Commonwealth has power constitutionally to deal---- Where the (state tax) base is the same and the rate unvarying, there is no lack of uniformity.’ ...

1994Id. at 169, 386 A.2d at 493 (citations omitted.) In this case it is clear that the state tax base for the year 1991 was the same and the rate unvarying for all corporations and, therefore, there was no -violation of the uniformity clause.

2024In Warner Brothers, for example, we rejected a Uniformity Clause challenge to a flat-dollar cap on deductions from corporate income. 45 Although this Court did not fully explain why the corporate deduction in Warner Brothers satisfied the Uniformity Clause while the individual exemptions in Cope’s Estate and Kelley did not, we would go on to clarify many years later that analogies between individual income taxes and corporate income taxes are “unpersuasive” because corporations “are artificial legal entities created with the permission of the state for the purpose of maximizing profits for sha

2024In Warner Brothers, for example, we rejected a Uniformity Clause challenge to a flat-dollar cap on deductions from corporate income. 45 Although this Court did not fully explain why the corporate deduction in Warner Brothers satisfied the Uniformity Clause while the individual exemptions in Cope’s Estate and Kelley did not, we would go on to clarify many years later that analogies between individual income taxes and corporate income taxes are “unpersuasive” because corporations “are artificial legal entities created with the permission of the state for the purpose of maximizing profits for sha

2003Article VIII, Section 1 of the Pennsylvania Constitution provides that "[a]ll taxes shall be uniform, upon the same class of subjects, within the territorial limits of the authority levying the tax, and shall be levied and collected under general laws." "In matters of taxation, allegations of violations of the equal protection clause of the United States Constitution and the uniformity clause of the Pennsylvania Constitution are analyzed in the same manner, requiring equality of burden upon classes or things subject to the tax in question." Equitable Life Assurance Society of the United States

2003Article VIII, Section 1 of the Pennsylvania Constitution provides that "[a]ll taxes shall be uniform, upon the same class of subjects, within the territorial limits of the authority levying the tax, and shall be levied and collected under general laws." "In matters of taxation, allegations of violations of the equal protection clause of the United States Constitution and the uniformity clause of the Pennsylvania Constitution are analyzed in the same manner, requiring equality of burden upon classes or things subject to the tax in question." Equitable Life Assurance Society of the United States