Dissenting Opinion by
Mr. Justice Eagen :While I wholeheartedly endorse the conclusion that appellant Dunbar is not exempt from payment of the instant tax, I do not agree with the Court’s determination with respect to the proper valuation of this property.
Like the majority I have plumbed the statute to determine the meaning of the word “value” which is used without accompanying definition in 72 P.S. §4821.1 My soundings, however, indicate that it was the intention of the legislature to tax these agreements at their real or market value.
Mr. Justice Frankfurterbest summarized the task at hand when he wrote, “Statutes come out of the past and aim at the future. They may carry implicit residues or mere hints of purpose. Perhaps the most delicate aspect of statutory construction is not to find more residues than are implicit nor purposes beyond the bound of hints.” Frankfurter, Some Reflections on the Reading of Statutes, 47 Colum. L. Rev. 527, 535.
*197One such, hint of purpose is found in Section 17 of the original Act which made scrip, bonds and certificates of indebtedness issued by private corporations taxable for state purposes “at the rate of four mills on each dollar of the nominal value thereof. . . .” (Emphasis supplied) Act of June 17, 1913, P. L. 507, §17.
Thus it is apparent that the legislature was capable of and did distinguish between “value” and “nominal value” in the various sections of the statute as originally enacted. Bee, also, 1 Pa. Taxes, GCH, §24-031.
Reinforcing an interpretation of “value” in the context of this statute to mean real or market value is the command of 72 P.S. §4843.1(a) (1) which states in part: “For the purpose of ascertaining the amount of tax payable under this act, it shall be the duty of every resident ... to transmit to . . . the county commissioners . . . the aggregate actual value of each part of the different classes of property made taxable by this act . . . possessed by such resident. . . .”
As was aptly pointed out by counsel for appellant, it would be useless to require a return of property at actual value and a taxation at face value.2
Moreover, this Court has on one occasion in the past in Commonwealth v. Lehigh Valley R. Co., 104 Pa. 89 (1883), considered the exact language which now troubles us in a very similar personal property tax statute. Involved was the Act of June 7, 1879, P. L. 112, §17, and the supplementary Act of June 10, 1881, which declared that mortgages, etc., “shall be and hereby are made taxable at the rate of four mills on every dollar of the value, thereof.” Unlike the instant case, the property tax was being levied for state as opposed to county purposes. There the Court said, at pp. 100, 101:
*198“The phrase, ‘every dollar of the value thereof/ has acquired a well established signification under our revenue system; it means simply the actual value, or worth.
“The Legislature has thus frequently defined the phrase ‘every dollar of the value thereof' to signifying actual value, and the construction which is deducible from the continued, general and uniform practice and understanding throughout the Commonwealth, is the same”'
The majority assert that adoption of a real or market value standard of valuation would fly in the face of long-standing precedent and direct our attention to certain language in Commonwealth v. Delaware Division Canal Co., 123 Pa. 594 (1889). Removed from the context and fabric of the case, the language concededly supports the majority’s view. But whether that case is dispositive of the present issue of valuation is best answered by noting that the tax under consideration there was imposed by explicit legislative directive “upon the nominal value” of corporate loans. The court there did nothing more than to declare the levy on the nominal value of the property a constitutionally permissible classification.
Nor do I believe that the McNeil Tax Assessment Case, 435 Pa. 553, 557, 257 A. 2d 835 (1969), advances the majority’s view on the question of valuation. Although this Court refused there to sanction the use of blockage, the actual or market value of the stock, as determined by the closing market price, was used for assessment purposes. Hence, McNeil cannot be made to serve the wider purpose of obstructing the use of real or market value as a measure of the tax in the instant case.
This is not to say that I would have the Board take into consideration all of the factors which Dunbar asserts affect such market value.
*199No consideration should be given to the number of agreements which Dunbar holds and the possible effect of disposing of all of them at one time. This is an undisguised attempt to invoke the blockage principle and is precluded by the McNeil decision.3 Nor should the credit of the obligors, a most nebulous concept when one considers that Dunbar is in the business of providing low cost housing to low income individuals, be taken into account unless exceptional circumstances can be shown. As long as an individual is solvent and paying on the agreement, this factor should not be added to the scales. It would admittedly be relevant in cases where the debtor is insolvent.
On the other hand, outstanding mortgages would affect the value of these agreements since the agreement holder is responsible for payment of the same. Likewise, it seems reasonable that the cost of servicing these agreements would be a factor which a willing buyer would take into consideration in the formulation of his offering price and hence should be a factor in an assessment.
It was also argued that many of the instruments of agreement were executed at a time when the interest rate prevailing in the money market was lower. Consequently, in order to achieve what is presently considered a reasonable yield on an investment, the prices paid for such instruments would necessarily be lower than face value in order to increase the yield to the instrument’s purchaser. If such could be proven by expert financial testimony, it would be pertinent to a determination of market value.
Mr. Justice Pomeroy joins in this dissent.“All personal property of the classes hereinafter enumerated . . . is hereby made taxable annually for county purposes ... at the rate of four mills of each dollar of the value thereof. . . .” (Emphasis supplied) Act of June 17, 1913, P. L. 507, §1, as amended, 72 P.S. §4821.
Tliat is, of course, unless the situation is one in which the actual value and the nominal or face value are identical.
I filed a dissenting opinion in McNeil and stand by the views expressed therein.