Dixon Estate

Opinion by

Mr. Justice Eagen,

This appeal involves the correctness of the appraisement of the Estate of Harold R. Dixon, deceased, by the Department of Revenue of the Commonwealth of Pennsylvania for inheritance tax purposes. For reasons that will appear later in this opinion, it is unnecessary to reach the merits of the controversy.

Dixon, the decedent, died testate in Allegheny County on June 1, 1968. Letters testamentary were issued by the Register of Wills on June 26th. The Estate filed an inheritance tax return on October 16th. The Department of Revenue filed its appraisement of the Estate…