OPINION
JONES, Chief Justice.
The executors of this estate petitioned the Orphans' Court Division to reduce the appraisement of certain assets made by the Commonwealth for purposes of imposing its transfer inheritance tax. The auditing judge sustained the taxpayers' position at a hearing held at the audit of the executors' account. 24 Fiduc.Rep. 352 (C.P. Allegheny, 1974). Exceptions having been dismissed by the court en banc, the Commonwealth appealed....
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