Downs Racing, L.P. v. Luzerne County

CourtCommonwealth Court of Pennsylvania
DecidedFebruary 3, 2026
Docket1752 C.D. 2024
StatusUnpublished
AuthorLeadbetter

This text of Downs Racing, L.P. v. Luzerne County (Downs Racing, L.P. v. Luzerne County) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Downs Racing, L.P. v. Luzerne County, (Pa. Ct. App. 2026).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

Downs Racing, L.P., d/b/a Mohegan : Sun Pocono, f/k/a Mohegan Sun at : Pocono Downs : : v. : No. 1752 C.D. 2024 : ARGUED: December 8, 2025 Luzerne County, Luzerne County : Treasurer, and Luzerne County : Division of Budget and Finance, : Appellants :

BEFORE: HONORABLE PATRICIA A. McCULLOUGH, Judge HONORABLE STACY WALLACE, Judge HONORABLE BONNIE BRIGANCE LEADBETTER, Senior Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY SENIOR JUDGE LEADBETTER FILED: February 3, 2026

Luzerne County, Luzerne County Treasurer, and Luzerne County Division of Budget and Finance (collectively, Luzerne) appeal from the order of the Court of Common Pleas of Luzerne County, granting the motion for summary judgment of Downs Racing, L.P., d/b/a Mohegan Sun Pocono, f/k/a Mohegan Sun at Pocono Downs (Mohegan). At issue in this long-running dispute is whether Mohegan owes hotel room rental tax on complimentary rooms provided to patrons, pursuant to the Third Class County Convention Center Authority Act (Act).1 We affirm.

1 Act of August 9, 1955, as amended, added by the Act of November 3, 1999, P.L. 461, 16 P.S. §§ 2399.1-2399.23. The Act was repealed by the Act of May 8, 2024, P.L. 50, No. 14 (effective July 8, 2024), and reenacted and recodified at 16 Pa.C.S. §§ 17301-17323. For ease of discussion, this opinion refers to the provisions of the prior Act, which were in place at the time of the assessment being appealed. I. The Act, Ordinance, and Regulations The Act authorizes third class counties to impose a hotel room rental tax to, among other things, “facilitate the development of a convention facility and” promote “tourism within the county.” Section 2399.2(a)(7) of the Act, 16 P.S. § 2399.2(a)(7). Section 2399.23(a) of the Act provides that the tax shall be imposed “on the consideration received by each operator of a hotel within the market area from each transaction of renting a room or rooms to accommodate transients.” 16 P.S. § 2399.23(a) (emphasis added).2 The Act further provides that “[t]he tax shall be collected by the operator from the patron of the room,” and “[t]he rate of tax imposed . . . shall not exceed [5%].” Section 2399.23(a)-(b) of the Act, 16 P.S. § 2399.23(a)-(b). Pursuant to this authority, Luzerne County enacted a Hotel Room Rental Tax Ordinance (Ordinance) in 1996, and subsequently promulgated Hotel Room Rental Tax Regulations (Regulations), imposing a 5% tax. See Reproduced Record (R.R.) at 1a-15a. Section B of the Regulations pertaining to the “Imposition of Tax” provides, in pertinent part:

1. Rate of Tax: The Hotel Room Rental Tax is imposed at the rate of five percent (5%) effective July 1, 1996 and will continue thereafter upon the consideration received by each operator of a hotel/inn within the County of Luzerne from each transaction of renting a room or rooms to a transient. As used herein, [r]enting shall mean the act of paying or being paid consideration, whether received in cash money or otherwise for occupancy.

2. Collection of Tax by Operator: The tax is to be collected by the operator of each hotel/inn, at the time of

2 The corresponding language in Luzerne County’s Hotel Room Rental Tax Ordinance (Ordinance) is nearly identical. See Ordinance § B.1.

2 payment, from each person who pays the consideration of renting a room.

Regulations § B.1-B.2 (emphasis added). Section D of the Regulations pertaining to “Items Subject to Tax,” states that “[t]he occupancy of any room, for consideration, . . . is subject to the tax.” Regulations § D. The Ordinance relies on hotel operators to self-report the information necessary to calculate the tax on forms furnished by the County Treasurer. Ordinance § E.1-E.5. Specifically, each month, an operator “shall report the amount of consideration received for the transactions during the month,” and “shall compute and pay to the Treasurer the taxes shown as due on the return[.]” Ordinance §§ E.4 & E.5. If an operator fails or refuses to collect the tax or fails to report and remit payment of any portion of the tax, “the County Treasurer shall proceed in such manner as he may deem best to obtain facts and information on which to base his estimate of the tax due[,]” and then issue an assessment, including interest. Regulations § H. Section J of the Regulations provides:

It is presumed that all rooms are subject to the tax until the contrary is established by accurate records from the operator. The burden of proving that the rent or occupancy received is not taxable is upon the operator and the operator must demonstrate same through accurate records. In any case where a hotel operator fails to maintain adequate records as required under these Regulations, any room for which there is not adequate records shall be deemed to be occupied for the entire period for which the supporting records are lacking.

The following definitions provided in Section 2399.23(j) of the Act are significant to the present dispute:

“Consideration” shall mean receipts, fees, charges, rentals, leases, cash, credits, property of any kind or nature or other

3 payment received by operators in exchange for or in consideration of the use or occupancy by a transient of a room or rooms in a hotel for a temporary period.

....

“Occupancy” shall mean the use or possession or the right to the use or possession by a person other than a permanent resident of a room in a hotel for any purpose or the right to the use or possession of the furnishings or to the services accompanying the use and possession of the room.

“Patron” shall mean any person who pays the consideration for the occupancy of a room or rooms in a hotel.

“Transaction” shall mean the activity involving the obtaining by a transient or patron of the use or occupancy of a hotel room from which consideration emanates to the operator under an express or an implied contract.

“Transient” shall mean an individual who obtains an accommodation in any hotel for himself by means of registering at the facility for the temporary occupancy of a room for the personal use of that individual by paying to the operator of the facility a fee in consideration therefor.

16 P.S. § 2399.23(j). The Ordinance repeats these definitions almost verbatim, see Ordinance § A, and the Regulations incorporate the definitions from the Ordinance, see Regulations § A. II. Factual and Procedural Background Mohegan is a Pennsylvania Limited Partnership and casino resort in Luzerne County which includes a hotel, casino, convention center, racing operation, spa, and multiple bars and restaurants. R.R. at 86a, 183a. Mohegan admittedly

4 offers a significant number of complimentary rooms to both patrons and potential patrons, including members of Mohegan’s loyalty program known as “Momentum.”3 Mohegan does so by providing recipients with an offer code which can be redeemed for a complimentary room. For years, Mohegan self-reported and paid the tax on all its rooms, including complimentary rooms. See R.R. at 340a; Luzerne’s Br. at 10. Mohegan stopped paying the tax on complimentary rooms in 2016 on the advice of counsel. R.R. at 340a. Two years later, Luzerne noticed a discrepancy in Mohegan’s reporting, namely that it “ceased remitting tax on a category of rooms it had previously treated as taxable,” that being complimentary rooms. Luzerne’s Br. at 11. See also R.R. at 340a-41a. After conducting a review as authorized by the Ordinance and Regulations, Luzerne issued Mohegan an assessment for $1,368,081.17 in unpaid taxes for complimentary rooms it provided to patrons from January 2016 through August 2018. R.R. at 33a.

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Downs Racing, L.P. v. Luzerne County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/downs-racing-lp-v-luzerne-county-pacommwct-2026.