Airpark International I v. Interboro School District

ARGUED: December 8, 1997 OPINION IN SUPPORT OF AFFIRMANCE This is an appeal by allowance from an order of the Commonwealth Court, reversing the order of the Delaware County Court of Common Pleas. For the following reasons, I would affirm. Appellants, Airpark International I, Colonial Airport Parking, Inc., Rama Construction Co., Inc, 621 North Governor Printz, Inc., and Smart Park, Inc., operate commercial parking lots in Tinicum Township, which lies within Interboro School District. On May 18, 1994, the School District adopted a ""Resolution to Adopt Parking Lot Tax"" pursuant to Section 2 of the Local Tax Enabling Act (LTEA), Act of December 31, 1965, P.L. 1257, as amended, 53 P.S. § 6902.1 Paragraph 3 of the Resolution provides: