Fidelity-Philadelphia Trust Company's Appeal

Opinion by Me.

Justice Linn,

These appeals require the construction of part of the amendment of 1939 1 to the personal property tax Act of 1913. 2 The Fidelity-Philadelphia Trust Company, with its principal office in Philadelphia, is co-trustee with another, domiciled in Montgomery County, of trusts administered in Philadelphia where the assets are kept. It made a return in Philadelphia on which the tax collecting authorities made a demand for the 4 mill tax on the total value returned. It also made a return in Montgomery County where the taxing authorities demanded a tax in the proportion that…