Estate of Rose

In my view, the decision of the majority of the Court in this case not only is erroneous but also will lead to unnecessary complications in the administration of decedents’ estates in Pennsylvania. Therefore, for the reasons which follow, I must respectfully dissent.

I. VALUATION OF INCOME IN RESPECT OF A DECEDENT

The initial problem presented by this case is one of valuation for Pennsylvania inheritance tax purposes of certain assets in a decedent’s estate. The value of an item of property subject to such taxation is fair market *72value as statutorily defined in the classic mold.1 Value as thus…