Miller's Estate

Opinion by

Mr. Chief Justice Kephart,

The estate of Charles Herbert Miller was assessed $1,-091.99 in State personal property taxes on shares of the General Reinsurance Corporation, a foreign insurance company doing business in this State. The executors challenged the assessment, and, on the refusal of the Department of Revenue to reassess, the Common Pleas Court of Huntingdon County reversed its action and exempted the stock from the tax. The Commonwealth appeals to this Court.

The State Personal Property Tax Act of June 22, 1935, P. L. 414, Section 3, as amended July 17, 1936 (First Ex.…