Pew Trust

Opinion by

Mr. Justice Benjamin R. Jones,

This appeal presents a problem in the field of apportionment; does a common stock distribution in 1954 by the Sun Oil Company to its stockholders, including this trust, unaccompanied by a contemporaneous capitalization of earnings, constitute an apportionable event under the Pennsylvania Rule of Apportionment?

On June 2,1932, Mary C. Pew created an inter vivos trust to which she transferred 40,000 shares of the common stock of the Sun Oil Company (herein called Company).1 Under the provisions of the trust instrument the settlor actually created two…