In December 2011, the Pennsylvania Supreme Court resolved an outstanding issue of whether the purchase of large MRI and PET/CT scan systems was subject to the commonwealth’s sales tax. In an opinion authored by Justice J. Michael Eakin, the court determined that such large systems were in fact subject to the state sales tax.

The case, which was composed of two consolidated appeals, is styled as Northeastern Pennsylvania Imaging Center v. Commonwealth of Pennsylvania . By its holding, the Supreme Court reversed the decision of the Commonwealth Court. The appellees were both entities that had previously purchased the large-scale scanning machines. All of the facts presented to the Supreme Court were stipulated by the parties.

Procedural Posture and Underlying Facts