In Re Estate of Gillespie

OPINION OF THE COURT

POMEROY, Justice.

These two appeals raise identical questions concerning the taxation of joint bank accounts under the Inheritance and Estate Tax Act of 1961 [the Act].1 Section 241 of the Act imposes a tax on the interest passing to the surviving party or parties to a joint tenancy on the death of *457one of the joint tenants. In each of these cases (Nos. 95 and 96) the Commonwealth has appealed from a ruling that a so-called “convenience account”, funded entirely by the surviving tenant, is not subject to the tax.

The facts in No. 95 are as follows. Anna Gillespie opened a…