Opperman's Estate (No. 2)

Opinion by

Mr. Justice Kephart,

This appeal is from the final decree of the Orphans’ Court of Allegheny County, following its adjudication of the executor’s account in the estate of A. C. Opperman, deceased.

At the time of his death, testator was the owner of 6,000 shares of the capital stock of the William Schuette Company, a corporation of the State of Delaware, and appellant sought to recover from his estate a four mills tax on the value of those shares during certain years when he owned them but had not paid that tax. It is an admitted fact that the corporation itself was authorized to carry…