In Re Estate of Pettenati

DOYLE, President Judge.

The Commonwealth of Pennsylvania, Department of Revenue (Commonwealth) appeals from an order of the Court of Common Pleas of Indiana County sustaining the appeal of Joseph Gabelli and holding that his bank account was not subject to Pennsylvania Inheritance Tax.

This appeal arises out of a savings account owned by Mr. Gabelli and Ms. Anna Pettenati, deceased, who was Gabelli’s sister. Upon the death of Pettenati, the Commonwealth issued a Notice of Inheritance Tax addressed to Gabelli, assessing inheritance tax on one-half of the balance in the account. Gabelli timely…