concurring.
I concur in the result but write separately because the majority, in holding that Filbern Manor has standing to appeal the tax assessment, relies only on Filbern Manor’s ownership of the improvements which it made to the real property. I believe that it is the duration of Filbern Man- or’s lease, namely 99 years, which confers upon Filbern Manor an equitable interest in the real property itself sufficient to grant it standing to appeal the tax assessment.
The Borough of West Newton (Borough) is the record owner of the real property which is the subject of Filbern Manor’s tax assessment appeal. Filbern Manor entered *667into a 99 year lease for the property with the Borough and thereafter constructed a subsidized housing development on the land. After Filbern Manor appealed the tax assessment imposed upon the property by the Westmoreland County Board of Assessment Appeals, taxing authorities intervened and filed motions to quash Filbern Manor’s appeal challenging standing. Trial court quashed the appeal, holding that Filbern Manor is not the owner of the property and therefore lacks standing to appeal the tax assessment.
Blue Knob Recreation, Inc. Appeal, 122 Pa.Commonwealth Ct. 156, 551 A.2d 9 (1988), petition for allowance of appeal denied, 522 Pa. 597, 562 A.2d 321 (1989), to which the majority points, addresses just the opposite of the problem before us. In Blue Knob, the question before the court was whether improvements built on real property owned by the commonwealth were taxable to the lessee. The court’s analysis was guided by the general rule that a lessee’s tax liability is based upon whether there are indicia that the title to the improvements, as well as the leasehold itself, remain in the lessee during the term. This court held that, because the lease indicated that improvements to the property passed to the lessor at the conclusion of the thirty-five year lease, title to the improvements was reserved to the lessee until expiration of the lease, and thereby taxable to the lessee.
Blue Knob dealt with the question of whether the lessee was liable for taxation of the improvements made on government property where there were no provisions in the lease as to payment of taxes on the improvements. In the case before us, there is no question that Filbern Manor, by lease, is obligated to pay the real estate taxes. The only issue remaining is who can challenge the amount of the tax assessment. Blue Knob, however, is instructive in the case before us because the court examined the length of the lease and the reversion of improvements to determine ownership of the improvements and indicated that these factors could indicate ownership of the real property itself.
*668The lease between Filbern Manor and the Borough is for 99 years. The duration of this lease is a clear indication that the parties intended to place ownership of the improvements and the real property in Filbern Manor for an extended period. This interest is a sufficient equitable interest in the property to grant lessee standing to appeal the tax assessment.
An equitable interest in real estate is subject to taxation. Appeals of Baltimore & Ohio Railroad, 405 Pa. 349, 175 A.2d 841 (1961). Because an equitable interest in real estate is subject to taxation, I believe that the owner of an equitable interest in real estate has standing under 518.11 to appeal the tax assessment.
. Section 5020-518.1 of the Law, as amended, 72 P.S. § 5020-518.1(a) provides in pertinent part as follows:
Any owner of real estate or taxable property in this Commonwealth, who may feel aggrieved by the last or any future assessment or valuation of his real estate or taxable property, may appeal from the decision of the county commissioners, acting as a board of revision, or the board of revision of taxes, or the Board of Property Assessment, Appeals and Review, in counties of the second class, as the case may be, to the court____