
    Argued December 4,
    affirmed December 31, 1974
    BARNUM, Appellant, v. DEPARTMENT OF REVENUE, Respondent.
    
    530 P2d 28
    
      William L. Dickson, Portland, argued the canse for appellant. With him on the briefs were Pozzi, Wilson & Atchison, Portland, and Alexander Schneider and Robert B. Carlson, of Schneider & Moultrie, Portland.
    
      Walter J. Apley, Assistant Attorney General, Salem, argued the canse for respondent. With him on the brief were Lee Johnson, Attorney General, and Theodore W. deLooze, Chief Tax Connsel, Salem.
    Before O’Connell, Chief Justice, and McAllister, Holman, Tongue, Howell, Bryson and Sloper, Jnstices.
   PER CURT AM.

The sole issue in this appeal from the decision of the Oregon Tax Court is whether an adopted child who is the beneficiary of the will of her natural father should be considered as a nonrelative and subject to the inheritance tax rate set forth in ORS 118.100 (3).

The Tax Court held that plaintiff was subject to the collateral tax imposed by ORS 118.100 (3) on nonrelatives. We agree with the decision of the Tax Court and adopt its opinion, 5 OTR 508 (1974). Any changes affecting the inheritance tax rates of persons in plaintiff’s position must necessarily come from the legislature.

Affirmed.  