Moreland Estate.

Opinion by

Me. Justice Hoeace Steen,

We are concerned here with questions as to the. application of certain provisions of the Tax Proration Act of July 2, 1937, P. L. 2762, to life insurance companies which had issued policies in favor of beneficiaries named by decedent or from which he had purchased annuities payable to such beneficiaries. An attack is also made upon the constitutionality of the act.

Thomas B. Moreland, a resident of Allegheny County, died April 13, 1942, leaving a will in which he made pecuniary bequests, inter alios, to his sister Margaret Moreland Porter, 1 his nephew T. B.…