Estate of Engle v. Commonwealth

Dissenting Opinion by

Judge Doyle:

The issue before the Court is not the value of the farmland for inheritance tax purposes. The Department of Revenue has no quarrel with giving the six tracts of farmland special preferential tax treatment to carry out the public policy of this Commonwealth, pronounced in Article 8, Section 2(b)(1) 2 of the Pennsylvania Constitution. That Section allows the General Assembly to “Establish standards . . . for . . . agriculture reserves, and land actively devoted to agricultural use, and make special provisions for the taxation thereof. . ,”1

What is before the…