The opinion
ORDER
PER CURIAM.
AND NOW, this 5th day of June 2014, the Petition and Cross Petition for Allowance of Appeal are GRANTED. The issues, as stated by the parties, are:
(1) Was President Judge Pellegrini correct in dissent that the majority’s conclusion — that although there is a very strict three-year statute of limitations on requests for tax refunds, there is no statute of limitations at all on requests for tax credits — is “absurd” in that it allows taxpayers to pursue tax overpayments against the City “forever,” without any limiting principles whatsoever?
(2) Whether, as a matter of law and equity, the Commonwealth Court correctly upheld the Philadelphia Court of Common Pleas by denying Taxpayers BPT refunds [under the circumstances]. 1
. The second issue has been shortened only to delete unnecessary detail.