Generally speaking, the Pennsylvania inheritance tax is applied to the pre-tax estate and not the estate after payment of the tax, and the pre-residuary gifts is paid from the residue. The Commonwealth Court has held that, when the residue is depleted by the tax on pre-residuary gifts, the tax rate to apply to the residue is the same rate that applies to the pre-residuary gifts, and the same rationale could apply to estate in which the residue is not depleted by the tax.