Hufnagel Estate

BOYLE, P. J.,

The case before the court involves an appeal from a transfer inheritance tax assessment.

The question presented is whether the Pennsylvania real property of a nonresident decedent, under agreement of sale at the date of her death, is subject to Pennsylvania transfer inheritance tax under the provisions of the Inheritance and Estate Tax Act of June 15, 1961, P.L. 373, sec. 212.

Decedent died July 6, 1967, a resident of Buenos Aires, Argentina. By her last will dated April 13, 1967, decedent gave all her estate to her three children, one-fifth to John R. Hufnagel, two-fifths to…