School Scholarships Limited to the Children of Faculty Members
In Wyoming Valley Montessori Association, Inc. v. Board of Assessment, 110 Pa. Commw. 458, 532 A.2d 931 (Pa. Cmwlth. 1987), there were no students who attended that school free of charge, scholarships were limited to the children of faculty members, only 5 children were receiving partial scholarships, and scholarships totaled less than 10% of the school's enrollment.
Our court determined that Wyoming did not make 'a bona fide effort to service primarily those who cannot afford the usual fee.' Id. at 933-934, citing, HUP, 507 Pa. at 19 n.9, 487 A.2d at 1315 n.9.
Our court in Wyoming further cited our Supreme Court in Pittsburgh Institute of Aeronautics Tax Exemption Case, 435 Pa. 618, 624, 258 A.2d 850, 853 (1969), and determined that "a school in which the admission of students is almost totally limited to those who are able to pay their own way can hardly be considered a charitable institution." Wyoming, 532 A.2d at 933.