DISSENTING OPINION BY
Senior Judge FRIEDMAN.I respectfully dissent. The majority holds that, because the Kosco Family Land Trust (Trust) has features of a business trust, it is not an “ordinary trust” within the definition in section 1101-C of the act known as the Realty Transfer Tax Act (Act)1 and, thus, is not exempt from realty transfer taxes. For the following reasons, I cannot agree.
*190Michael A. Kosco and Sally R. Kosco (Taxpayers) built a retirement home designed to accommodate visits from their four children and their families. In February 2006, Taxpayers executed the Trust, making Taxpayers both trustees and beneficiaries and making their four children secondary beneficiaries. In May 2006, Taxpayers transferred the home to the Trust for no actual consideration.
Realty transfer taxes are not imposed upon:
A transfer for no or nominal actual consideration to a trustee of an ordinary trust where the transfer of the same property would be exempt if the transfer was made directly from the grantor to all of the possible beneficiaries[2] that are entitled to receive the property or proceeds from the sale of the property under the trust, whether or not such beneficiaries are contingent or specifically named.
72 P.S. § 8102-C.3(8) (emphasis added). Section 1101-C of the Act defines an “ordinary trust” as follows:
Any trust, other than a business trust or a living trust, which takes effect during the lifetime of the settlor and for which the trustees of the trust take title to property primarily for the purpose of protecting, managing or conserving it until distribution to the named beneficiaries of the trust. An ordinary trust does not include a trust that has an objective to carry on business and divide gains, nor does it either expressly or impliedly have any of the following features: the treatment of beneficiaries as associates, the treatment of the interests in the trust as personal property, the free transferability of beneficial interests in the trust, centralized management by the trustee or the beneficiaries, or continuity of life.
72 P.S. § 8101-C.
The majority concludes that an objective of the Trust is to carry on a business and that the Trust has features of a business trust because the Trust “authorizes the renting, mortgaging, selling or other disposition of the Trust realty.” (Majority op. at 189.) However, ordinary homeowners rent, mortgage, sell and dispose of their real property, and they are not carrying on a business. Thus, I cannot agree that the Trust is a business trust simply because it authorizes trustees to do with the Trust property what ordinary people do with their property.
Accordingly, I would reverse.
. Act of March 4, 1971, P.L. 6, as amended, added by the Act of May 5, 1981, P.L. 36, as amended, 72 P.S. § 8101-C.
. Realty transfer taxes are not imposed upon intra-family transfers. Section 1102-C.3(6) of the Act, added by the Act of July 2, 1986, P.L. 318, as amended, 72 P.S. § 8102-C.3(6). Thus, in this case, the transfer would be exempt.