The City of Allentown, PA, cannot impose a business privilege tax on revenue received by the parent entity of a healthcare system from providing services to its nonprofit affiliates. A trial court has held that the activity is not engaged in for profit and is therefore not subject to the tax. The City of Allentown imposes a business privilege tax on any activity “carried on or exercised for gain or profit in the City, including … the sale of merchandise or other tangible personality or the performance of services.” The Good Shepherd Rehabilitation Network is the parent entity of a system that includes a rehabilitation hospital, a long-term care facility, a long-term acute care service...