Amon Estate

1 Pa. D. & C.3d 479, 1976 Pa. Dist. & Cnty. Dec. LEXIS 124
CourtPennsylvania Court of Common Pleas, Montgomery County
DecidedDecember 6, 1976
Docketno. 78080
StatusPublished
Cited by1 cases

This text of 1 Pa. D. & C.3d 479 (Amon Estate) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Montgomery County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Amon Estate, 1 Pa. D. & C.3d 479, 1976 Pa. Dist. & Cnty. Dec. LEXIS 124 (Pa. Super. Ct. 1976).

Opinion

TAXIS, J.,

William Hogan, Sr. and Kathleen H. Bucci, petitioners, are decedent’s residuary legatees. The petition seeks to strike off the election to take against the will filed by decedent’s spouse, Harry G. Amon. The grounds are that the election was filed more than six months (actually six months and 22 days) after the grant of letters, which allegedly violates the requirements of section 2511 of the Probate, Estates and Fiduciaries Code of June 30, 1972, P.L. 508 (No. 164), 20 P.S. §2511.

*A hearing was held on September 27, 1976, and the matter has been argued and briefs submitted. The issues before the court are whether or not the statutory time limit may be extended by the court for cause shown and, if so, what facts or circumstances constitute such cause.

Harry G. Amon and decedent owned their residence as tenants by the entireties. In addition to acquiring sole title to this property through his wife’s death, Mr. Amon was left some personal items, including a car, by the will, and decedent also therein created a $50,000 trust for him for his lifetime. Decedent had inherited the bulk of her estate from a deceased brother, and felt impelled to retain the assets substantially in her own family. Her will had been drawn by Desmond J. McTighe, Esquire, in 1971, and he is now counsel for the executrix, Mary Ellen Moore. Shortly after decedent’s death Mr. Amon, in cooperation with Mrs. Moore, withdrew the contents of his and de[481]*481cedent’s joint safe deposit box and delivered them to Mr. McTighe’s office. Mr. Amon also cooperated in the appraisal of the residence and the personal effects in it belonging to decedent, as required for tax purposes. Also, in the course of the estate administration, Mr. McTighe collected the proceeds due Mr. Amon from three insurance policies on decedent’s life, which matters Mr. McTighe took care of without charge, mainly to obtain the necessary information for proper tax treatment of the insurance proceeds in the' State and Federal death tax returns. However, Mr. Amon never actually met with Mr. McTighe after decedent’s death, and it is clear that Mr. McTighe relied upon the executrix to communicate with Mr. Amon as necessary, as illustrated by the fact that the deed to the property was returned to Mr. Amon by Mr. McTighe, through Mrs. Moore.

Mr. McTighe testified that he and Mrs. Moore had discussed the right of Mr. Amon to elect to take against the will, but that neither he nor Mrs. Moore had at any time informed or advised Mr. Amon of his right to do so, or about the size of the estate or of the advisability of consulting counsel of his own. His entirely proper explanation for this was that he had represented Mrs. Amon in preparing the will and is presently representing the estate, in which circumstances his primary obligation is to defend and implement the will and not to assist in rendering part of it ineffective. Mr. Amon had a copy of and knew about the will, but testified that although he thought it was unusual and did not care for it, he did not decide to do anything about it until after the six-month elective period had expired.

In 1950, Mr. Amon had consulted M. Paul [482]*482Smith, Esquire by himself, for the preparation of a will. At that time, it appears that he and Mr. Smith discussed the rights of Mrs. Amon to elect against his will, but Mr. Amon was not made aware at that time that he had a corresponding right against his wife’s will. Mr. Smith’s notes do not indicate that Mr. Amon was ever told of any time limits on such a right. Mr. Amon returned to Mr. Smith in 1968 for a minor change to the will. On August 13, 1976, he went again to Mr. Smith’s office for the preparation of a new will, and there learned of his elective rights. The present election followed promptly, three days later.

Harry G. Amon is now eighty-four years of age. He testified that he had only an eighth-grade education. Physically, he suffers from circulatory problems, but these are perhaps not unusual for a man of his age. At the hearing, he impressed the court with the clarity of his mind and the responsiveness of his answers, and he is clearly competent and credible.

The applicable Statute pertinently provides:

“As between the surviving spouse and other legatees and devisees, the spouse’s election shall be in time if within six months after the probate of will the surviving spouse shall [elect to take against it] . . .”

Subsequent language permits this court, upon application within six months, to extend the time for making such an election, but the act is otherwise silent as to the permissibility of and basis for extending the time after the expiration of the six-month period. Although the language “. . . shall be in time if within six months . . . ,” may be referring only to the power granted to the court to extend the time, it nevertheless appears that other facts and [483]*483circumstances may warrant an extension even though not applied for within the six-month period.

The principal basis dealt with by the reported cases is where “actual fraud” against the electing spouse is present: Freer Est., 353 Pa. 351, 45 A.2d 47 (1946). However, if “actual fraud” in a strict sense were always required, extensions of the six-month period on equitable grounds would be few and far between. In most such cases utilizing this ground to deny an extension, such as DiMarco Est., 435 Pa. 428, 257 A.2d 849 (1969), and Faller Est., 407 Pa. 73, 180 A.2d 33 (1962), the electing spouse had sufficient knowledge of the circumstances surrounding the administration of the deceased spouse’s estate to have enabled any normally prudent person to determine his or her rights and to act upon them, so that he or she was not entitled to equitable relief. Moreover, in most of the cases the extension sought was for months and occasionally for years, not, as here, for 22 days.

This court does not subscribe to the rule, suggested by the argument of the surviving spouse, that the executrix or her counsel owed a fiduciary duty to Harry G, Amon to advise him of his right to elect against the will and to disclose to him the estate’s size and value. In spite of recent statutory revisions in this and other areas of Pennsylvania probate law and the nationwide circulation of the proposed Uniform Probate Code, there is no authority, either in existence or proposed, which imposes such a duty generally. In Fiduciary Review, March 1967, it is said:

“If the executor and his counsel must fully inform the surviving spouse of his or her elective rights and of the relative choices available, the [484]*484burden of doing so in some situations may be onerous, especially when inter vivos transfers subject to the provisions of Section 11 of the Estates Act of 1947 may be involved. There is the further factor that an attorney-scrivener as well as the executor may consider themselves under an obligation of loyalty to the wishes of their employer-testator.”

This statement was made in reviewing Rowe Est., 17 Fiduc. Rep. 107 (1967), wherein the Court said, at page 110:

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Related

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Bluebook (online)
1 Pa. D. & C.3d 479, 1976 Pa. Dist. & Cnty. Dec. LEXIS 124, Counsel Stack Legal Research, https://law.counselstack.com/opinion/amon-estate-pactcomplmontgo-1976.