Caflisch's Estate

21 Pa. D. & C. 282, 1933 Pa. Dist. & Cnty. Dec. LEXIS 10
CourtPennsylvania Court of Common Pleas, Erie County
DecidedNovember 9, 1933
StatusPublished

This text of 21 Pa. D. & C. 282 (Caflisch's Estate) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Erie County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Caflisch's Estate, 21 Pa. D. & C. 282, 1933 Pa. Dist. & Cnty. Dec. LEXIS 10 (Pa. Super. Ct. 1933).

Opinion

Waite, P. J.,

This matter comes before the court on the audit of an account of Margaret E. Caflisch and Jacob C. Caflisch, executors of the estate of Jacob C. Caflisch, alias J. C. Caflisch, deceased, filed January 13, 1933.

The Commonwealth of Pennsylvania has presented a claim for an estate tax in the sum of $44,589.90, under the provisions of the Act of May 7, 1927, P. L. 859. The amount of this tax is made up as follows: $27,524.63 estate tax claimed, and $17,065.27 penalty on same, figured at the rate of 12 percent per annum from July 9, 1928, being 1 year after decedent’s death, to September 9, 1933.

J. C. Caflisch, a resident of the Borough of Union City, Pa., died July 9,1927. On July 14, 1927, his last will and testament was probated in the office of the register of wills of this county. Immediate steps were taken to have an inventory made, appraisers were appointed, and the inventory was made as of July 19, 1927, and the same was filed in the register of wills’ office of this county on July 27,1927.

On September 10, 1927, an appraisement for transfer inheritance tax purposes was filed, and on September 30,1927, less than 3 months from the date of the death of J. C. Caflisch, a transfer inheritance tax in the amount of $17,921.30 was paid, as is evidenced by a receipt for that amount filed with the account. The receipt is signed by the then register of wills of Erie County, and sealed and countersigned by the Auditor General of the Commonwealth of Pennsylvania.

From the history of the case this far, it is evident that no delays were intended on the part of the executors. It is a fact that the account was not filed until [283]*283more than 5 years had lapsed, but there is nothing unusual about that. It was explained in the testimony taken at the time of the audit that there was sufficient reason for the postponing of the filing of the account. The assets of this estate were somewhat involved in litigation, and large sums due the estate were found to be uncollectible. After creditors were paid, the only two who could be injured by the postponing of the filing of the account are the widow and the son, who are the only legatees under the will, and they are not complaining.

After the filing of the account, to wit, August 29, 1933, a so-called “supplemental appraisement” was filed in the office of the register of wills, setting forth the amount of the estate tax due the Commonwealth of Pennsylvania and the manner in which same was arrived at. On the same date, a claim for estate tax in the sum of $27,524.63, together with a penalty in the sum of $17,065.27, or a total of $44,589.90, was made upon the executors.

This claim is based on the provisions of the Act of May 7, 1927, P..L. 859, which provides for the collection of the estate tax as follows:

“That in order that the Commonwealth may receive the benefit of section three hundred and one (b) of the Federal Revenue Act of nineteen hundred and twenty-six, or any other legislation of a similar kind or enacted for a like purpose, which grants a credit on the Federal estate tax for inheritance taxes and transfer inheritance taxes paid to the state governments, additional transfer taxes for State purposes are hereby imposed upon the transfer, in trust or otherwise, of any property taxable under the provisions of the transfer inheritance tax laws of this Commonwealth, . . . Such taxes shall be imposed and be collected, in accordance with the provisions of the transfer inheritance tax laws of the Commonwealth, in the following cases, viz: Whenever in any estate the total tax paid or payable to the Commonwealth and any other States or territory, at the rates fixed under the inheritance tax law, shall be less than the total credit allowed by the Federal law for taxes paid to the states, then the tax imposed by this act upon the transfer of such property shall be an amount equal to the difference between the total credit, allowable by the Federal law for taxes payable to the state governments, and the total taxes actually paid or payable to the Commonwealth and any other state or territory under the inheritance tax laws. . . .”

The Federal Act of February 26, 1926, c. 27, see. 301, 44 Stat. at L. 9, 26 U. S. C. §§1092,1093, provides as follows:

“ (a) In lieu of the tax imposed by Title m of the Revenue Act of 1924, a tax equal to the sum of the following percentages of the value of the net estate (determined as provided in section 303) is hereby imposed upon the transfer of the net estate of every decedent dying after the enactment of this act, whether a resident or nonresident of the United States; . . . [Schedule of Rates]
“ (b) The tax imposed by this section shall be credited with the amount of any estate, inheritance, legacy, or succession taxes actually paid to any State or Territory or the District of Columbia, in respect of any property included in the gross estate. The credit allowed by this subdivision shall not exceed 80 per centum of the tax imposed by this section, and shall include only such taxes as were actually paid and credit therefor claimed within three years after the filing of the return required by section 304.”

When an estate exceeds the amount of $100,000, so as to come under the provisions of the Federal Estate Tax Act of 1926, the orderly procedure is first to determine and pay the normal transfer inheritance tax due the Commonwealth of Pennsylvania. The proper report should then be filed with the Federal Government and a copy thereof filed with the register of wills, as is now provided [284]*284by the Act of May 16,1929, P. L. 1782. If, after deducting the $100,000 specific exemption allowed by the Federal Government and the 80 percent credit allowed for inheritance taxes paid to this Commonwealth and to any other State or Territory, it is found that the amount of inheritance taxes paid to the Commonwealth of Pennsylvania and to any other State or Territory does not equal the said 80 percent credit allowed, then the estate shall pay to the Federal Government the remaining 20 percent of the amount determined to be due and shall pay to the Commonwealth the difference between the 80 percent credit allowed and the normal transfer inheritance tax already paid to the Commonwealth. If, by error, more than 20 percent is paid to the Federal Government, claim for refund of the overpayment can be made within 3 years after the payment of the amount sought to be refunded. See section 319, art. xcix, Federal Revenue Act of 1926. But such erroneous payment does not exempt the estate from payment of any estate tax due the Commonwealth of Pennsylvania under the Act of 1927.

In Knowles’ Estate, 295 Pa. 571, 576-577, Mr. Chief Justice Moschzisker, discussing this legislation, said:

“The United States Revenue Act of 1926 provides, by section 301 (b), 44 Stat. 70, (U. S. C. A. Tit. 26, section 1093) as follows: ‘The tax imposed by this section shall be credited with the amount of any estate, inheritance, legacy, or succession taxes actually paid to any state or territory or the District of Columbia, in respect of any property included in the gross estate. The credit allowed . . . shall not exceed eighty per centum of the tax imposed.’ By this statute, the federal government has declared it to be the national policy that the net value of all estates (in excess of $100,000, that amount being exempt: Section 303 (a) 4, 44 Stat. 72, U. S. C. A. Tit.

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Related

Knowles's Estate
145 A. 797 (Supreme Court of Pennsylvania, 1929)

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Bluebook (online)
21 Pa. D. & C. 282, 1933 Pa. Dist. & Cnty. Dec. LEXIS 10, Counsel Stack Legal Research, https://law.counselstack.com/opinion/caflischs-estate-pactcomplerie-1933.