Arrott's Estate

Opinion by

Mr. Chief Justice Kephart,

The County of Allegheny claimed from the Estate of James W. Arrott, Jr., deceased, personal property taxes on stock held by decedent in the American Radiator and Standard Sanitary Company, a corporation of the State of Delaware. The county states that upward of $3,000,-000 will come into the treasury from this and other taxables if its claim is sustained. The court below held the shares could not be taxed under the personal property tax act because the company must pay the franchise tax imposed oh foreign corporations by the Act of May 16, 1935, P. L. 184.

As…