Johnson's Estate

Opinion by

Mr. Justice Linn,

This appeal is from an assessment of inheritance tax under the Act of June 20, 1919, P. L. 521, 72 PS section 2301 et seq. as amended. Section 1 provides: “That a tax shall be, and is hereby, imposed upon the transfer of any property, real or personal, or of any interest therein or income therefrom, in trust or otherwise, to persons or corporations in the following cases: . . . (c) When the transfer is ... of goods, wares, and merchandise within this Commonwealth, . . . made by a nonresident, by deed, grant, bargain, sale, or gift, made in contemplation of the death…