Pennsylvania Co., Etc., Trustee, Case

Opinion by

Mb. Justice Parker,

Appellee, as trustee for an investment trust, on January 1,1940, held shares of twelve foreign insurance companies which had been authorized to do business in Pennsylvania and were subject to and had been paying a two per cent tax on gross premiums received from business done within this Commonwealth. The tax was imposed under section 24 of the Act of June 1, 1889, P. L. 420, as amended (72 PS §2261). The Department of Revenue assessed against the trustee the state personal property tax on these shares. On appeal, a court of common pleas held that the tax sought…