Commonwealth Trust Co.'s Appeal

Dithrich, J.,

This appeal from the decision of the Department of Revenue of Pennsylvania, sustaining an assessment of personal property tax against the petitioner for the year 1940, has been submitted to the court upon the following agreed facts and question of law:

“1. Exhibit no. 1 attached to the petition for appeal is a true and correct copy of an original agreement entered into on June 5, 1936, between Charles S. Todd, who upon said date was a resident of the City of Pittsburgh, County of Allegheny, Pa., and Commonwealth Trust Company of Pittsburgh.

“The securities deposited by said Charles…