OPINION
SAYLOR, Justice.
This is a direct appeal from the Commonwealth Court's order sustaining the preliminary objections of the Commonwealth of Pennsylvania, Department of Revenue to the petition for review filed by Appellant, Doris Parsowith, which sought a declaration that a portion of the Inheritance and Estate Tax Act, 72 P.S. §§ 9101-9196 (the "Act"), is unconstitutional.
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