430 Stump Road, LLP v. Com. of PA

CourtCommonwealth Court of Pennsylvania
DecidedMay 15, 2025
Docket502 F.R. 2022
StatusUnpublished

This text of 430 Stump Road, LLP v. Com. of PA (430 Stump Road, LLP v. Com. of PA) is published on Counsel Stack Legal Research, covering Commonwealth Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
430 Stump Road, LLP v. Com. of PA, (Pa. Ct. App. 2025).

Opinion

IN THE COMMONWEALTH COURT OF PENNSYLVANIA

430 Stump Road, LLP, : Petitioner : : v. : : Commonwealth of Pennsylvania, : No. 502 F.R. 2022 Respondent : Submitted: March 5, 2025

BEFORE: HONORABLE RENÉE COHN JUBELIRER, President Judge HONORABLE ANNE E. COVEY, Judge HONORABLE MICHAEL H. WOJCIK, Judge HONORABLE CHRISTINE FIZZANO CANNON, Judge HONORABLE LORI A. DUMAS, Judge HONORABLE STACY WALLACE, Judge HONORABLE MATTHEW S. WOLF, Judge

OPINION NOT REPORTED

MEMORANDUM OPINION BY JUDGE FIZZANO CANNON FILED: May 15, 2025

This case is before the Court en banc for consideration of exceptions filed by the Commonwealth of Pennsylvania (Commonwealth) from a panel decision of this Court. The panel reversed a determination of the Department of Finance and Revenue (F&R) that imposed a real estate transfer tax on a transfer of an interest in a real estate company, 430 Stump Road, LLP (Stump LLP). The reported panel decision provides detailed background and analysis, which are repeated here only to the extent necessary to this opinion. The Commonwealth excepts to nearly every aspect of the panel decision. After thorough review, we overrule the Commonwealth’s exceptions and direct the entry of final judgment in favor of Stump LLP. I. Background In 1994, Stump LLP purchased real property located at 430 Stump Road, Montgomeryville, Pennsylvania (Real Property). 430 Stump Road, LLP, No. 2200071 (F&R Aug. 25, 2022) (F&R Dec.), at 1. Stump LLP is a limited liability partnership and is a “real estate company” as that term is defined in Section 1101-C of the Tax Reform Code of 1971 (Tax Code),1 72 P.S. § 8101-C.2 Joint Stipulation of Facts filed Nov. 29, 2023 (Stip.) at 2. Prior to the death of Allen Kanter (Settlor), the Allen L. Kanter Revocable Trust (Revocable Trust) owned 98% of Stump LLP. Id. The terms of the Revocable Trust designated a second trust, the Allen L. Kanter Marital Trust FBO Valentina Kanter (Marital Trust), as the beneficiary to receive the Revocable Trust’s 98% partnership interest in Stump LLP after Settlor’s death. Id. at 3. Settlor’s wife was the beneficiary of the Marital Trust. Id. In March 2017, upon Settlor’s death, the Revocable Trust transferred its partnership interest in Stump LLP to the Marital Trust. Id. In September 2021, the Department of Revenue, Bureau of Individual Taxes (“Department”), issued a Notice of Assessment to Stump LLP, imposing real estate transfer tax on the computed value of the Real Property. F&R Dec. at 1-2. The Department reasoned that the transaction was subject to real estate transfer tax because it was not a transfer of real estate due to merger. Id. at 2. Stump LLP petitioned for review by the Bureau of Appeals (BOA), arguing that the transfer was not subject to the transfer tax because it was a transfer from the trustee of a living trust to the beneficiary of a living trust. F&R Dec. at 2. The BOA rejected that argument and sustained the transfer tax assessment, positing

1 Act of March 4, 1971, P.L. 6, as amended, 72 P.S. §§ 7101-10004. 2 Added by the Act of May 5, 1981, P.L. 36.

2 that the exception advanced by Stump LLP applies only to a direct transfer of realty, not to the transfer of an interest in a real estate company. Id. The BOA likewise rejected Stump LLP’s argument that the transfer involved no change in ownership as the beneficiaries of the two trusts were the same; the BOA stated that a trust itself does not have owners, and as a transfer of a 98% interest in Stump LLP, a real estate company, was made between the trusts, the Department properly assessed tax on the computed value of the Real Property held by Stump LLP. Id. Stump LLP filed a petition for relief with F&R, which denied the petition. F&R Dec. at 5. Addressing Stump LLP’s argument that the transfer was not subject to transfer tax because it was a transfer from a trustee of a living trust to the beneficiary of a living trust, F&R upheld the Department’s application of the tax because the transfer at issue was not an actual transfer of an interest in real estate, but a transfer of an ownership interest in a real estate company, which the Department concluded was subject to tax. Id. at 6. F&R also found that Stump LLP failed to present sufficient evidence to support its claims that the Department’s applicable regulation was improperly promulgated and conflicts with the authorizing statute. Id. F&R similarly rejected Stump LLP’s contention that the transfer was not subject to tax because there was no change in ownership or because the transfer was between members of the same family. Id. Stump LLP then filed a petition for review in this Court, which reversed in a three-judge panel decision. See 430 Stump Rd., LLP v. Commonwealth of Pa., 319 A.3d 626 (Pa. Cmwlth. 2024) (Panel Dec.). First, the panel agreed with Stump LLP that the Revocable Trust’s transfer of its 98% interest in Stump LLP to the Marital Trust after Settlor’s death was not subject to the real estate transfer tax because it constituted a transfer from the trustee of a living trust after the death of

3 the settlor, pursuant to Section 1102-C.3(9.1) of the Tax Code, 72 P.S. § 8102- C.3(9.1).3 Panel Dec., 319 A.3d at 632. Further, the panel determined that F&R’s application of Section 91.193(b)(34) of its regulations, 61 Pa. Code § 91.193(b)(34), was not consistent with that conclusion and was, therefore, improper and would be disregarded. Panel Dec., 319 A.3d at 632. The panel concluded as a matter of law that Stump LLP had sustained its burden of proving that no transfer tax was owed. Id. at 633. The Commonwealth filed exceptions, which are before us en banc.4

II. Relevant Statutes and Regulations Section 1102-C of the Tax Code provides: Every person who makes, executes, delivers, accepts or presents for recording any document or in whose behalf any document is made, executed, delivered, accepted or presented for recording, shall be subject to pay for and in respect to the transaction or any part thereof, or for or in respect of the vellum parchment or paper upon which such document is written or printed, a State tax at the rate of one per cent of the value of the real estate within this Commonwealth represented by such document, which State tax shall be payable at the earlier of the time the document is presented for recording or within thirty days

3 Added by the Act of July 2, 1986, P.L. 318. 4 “In tax appeals from [F&R], this Court functions as a trial court, and exceptions filed to its final order have the effect of an order granting reconsideration.” Am. Elec. Power Serv. Corp. v. Commonwealth of Pa., 184 A.3d 1031, 1034 n.7 (Pa. Cmwlth. 2018) (citing Consol. Rail Corp. v. Commonwealth of Pa., 679 A.2d 303, 304 (Pa. Cmwlth. 1996)). We review determinations of F&R de novo. Am. Elec. Power, 184 A.3d at 1034 n.7 (citing Kelleher v. Commonwealth of Pa., 704 A.2d 729, 731 (Pa. Cmwlth. 1997)). However, our review in tax appeals is limited to the construction, interpretation and application of state tax laws to a given set of facts. Am. Elec. Power, 184 A.3d at 1034 n.7 (quoting United Servs. Auto. Ass’n v. Commonwealth of Pa., 618 A.2d 1155, 1156 (Pa. Cmwlth. 1992) (quotation marks omitted) (additional citation omitted)).

4 of acceptance of such document or within thirty days of becoming an acquired company. 72 P.S. § 8102-C.

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