All Issues Waived on Appeal 

Tax Alert

June 30, 2014

A panel of the Commonwealth Court held that a pro se taxpayer waived all issues on appeal because he failed to comply with the lower court’s order directing him to file a statement of matters complained of on appeal. City of Philadelphia v. Tax Review Board, Appeal of Samuel Cook, No. 1070 C.D. 2013 (Pa. Commw. May 21, 2014) (unreported). Issues not stated in a statement are waived. Commonwealth v. Castillo, 888 A.2d 775 (Pa. 2005). Since the taxpayer filed no statement, all issues were waived.  

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Authors

Joseph C. Bright

Member

jbright@cozen.com

(215) 665-2053

Dan A. Schulder

Member

dschulder@cozen.com

(717) 703-5905

Cheryl A. Upham

Vice Chair, Tax

cupham@cozen.com

(215) 665-4193

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To discuss any questions you may have regarding the opinion discussed in this Alert, or how it may apply to your particular circumstances, please contact: Joseph C. Bright at jbright@cozen.com or 215.665.2053, Dan A. Schulder at dschulder@cozen.com or 717.703.5905 or Cheryl A. Upham at cupham@cozen.com or 215.665.4193.