Mercer Estate

Opinion by

Mb. Justice Cohen,

Appellants, executors of the Estate of Mary Whitner Mercer, complain of a decree of the Orphans’ Court of Berks County which dismissed their appeal from the transfer inheritance tax appraisement of 3% noncumulative second preferred stock belonging to the decedent at its par value of $100 a share.

*497The Act of June 20, 1919, P. L. 521, as amended, 72 PS §2301 et seq., imposes an inheritance tax upon the transfer of property by will and provides “All taxes imposed by this Act shall be imposed upon the clear value of the property subject to the tax. . . .”

Appellants…