(dissenting).
I dissent. The evidence in this case is clear that appellee never intended to transfer any ownership interests or rights to the decedent. The joint account had been set up as a convenience account only. Under Section 241 of the Act of June 15, 1961, P.L. 373, 72 P.S. § 2485-241 (1964), a transfer subject to tax is defined as the accrual of the right to the immediate ownership or possession and enjoyment of the whole property upon the death of one of the joint tenants. Since appellee never intended to transfer any money or rights to the decedent, she could not, upon the death of the decedent, have accrued any rights which she did not already possess. See In re Estate of Gillespie, 462 Pa. 467, 341 A.2d 471 (1975) (Manderino, J., dissenting). Thus, there was no transfer upon which the tax could be imposed.
NIX, J., joins in this dissenting opinion.