Glessner's Estate

40 Pa. D. & C. 271, 1940 Pa. Dist. & Cnty. Dec. LEXIS 58
CourtPennsylvania Orphans' Court, Montgomery County
DecidedSeptember 18, 1940
Docketno. 45787
StatusPublished

This text of 40 Pa. D. & C. 271 (Glessner's Estate) is published on Counsel Stack Legal Research, covering Pennsylvania Orphans' Court, Montgomery County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Glessner's Estate, 40 Pa. D. & C. 271, 1940 Pa. Dist. & Cnty. Dec. LEXIS 58 (Pa. Super. Ct. 1940).

Opinion

Sheely, P. J.,

fifty-first judicial district, specially presiding,

. . . The real question [273]*273raised by exceptant is one of distribution. She contends that by certain transactions between decedent and her son, George O. Glessner, and between decedent and her daughter, Florence L. Holt, the legacies of George O. Glessner and Florence L. Holt under the will have been satisfied in whole or in part. She contends that for the purpose of distribution the amounts involved in these transactions must be brought into account and charged against the distributive shares of the children named.

This contention is based upon the presumption that a parent intends to make equal distribution of his estate among his children and does not intend that the portion provided for any child shall be paid more than once. If, during the lifetime of the decedent, property is transferred to one child, it is presumed that the transfer was made in anticipation of the amount that child would likely receive from the estate of the decedent and as a prepayment thereof. As expressed by some of the cases, decedent becomes his own executor and makes a partial distribution of his estate in his lifetime: see 2 Pomeroy’s Equity Jurisprudence 1025, sec. 554. If decedent dies intestate these prepayments are considered advancements: M’Kibbin’s Estate, 207 Pa. 1 (1903); Eshleman’s Appeal, 74 Pa. 42, 47 (1873) ; Intestate Act of June 7,1917, P. L. 429, sec. 22. If decedent dies testate the prepayments are considered as satisfactions of the legacies to the payees: Miner et ux. v. Atherton’s Exec., 35 Pa. 528 (1860). In each case the rule is closely analogous to the rule of ademption of specific legacies and the terms are frequently used interchangeably, probably because the three propositions are based on the theory that decedent did not intend to provide doubly for the object of his bounty: see Alexander’s Estate, 83 Pa. Superior Ct. 210 (1924).

The rule is stated in Miner et ux. v. Atherton’s Exec., supra, p. 536:

“A legacy by a father to a child is understood as a portion, because it is a provision by a parent for his child. [274]*274If the father afterwards advances a portion for that child, it will be an ademption of that legacy, in whole or in part, as the advancements are larger, or equal to, or less, than the testamentary portion.”

In Eshleman’s Appeal, supra, p. 47, it was said:

“The general doctrine unquestionably is, that an advancement is an irrevocable gift by a parent to a child, of the whole or a part of what it is supposed the child will be entitled to upon the death of the parent, who after-wards dies intestate.”

And, in Patterson’s Appeal, 128 Pa. 269, 280 (1889), it was said:

“In the absence of expressions clearly indicating a contrary intention, the courts will presume that the testator intended equality of distribution among his own children, in accordance with the settled policy of the law in this commonwealth: Weaver’s App., 63 Pa. 309. As between a loan, a gift and an advancement, the presumption is in favor of an advancement, because of' its tendency to equality: Sampson v. Sampson, 4 S. & R. 329.”

There is nothing in this rule to prevent a parent from making an unequal distribution of his estate among his children or from making a gift to one child during his lifetime without disturbing the distribution of his estate after his death. The rule merely creates a presumption of fact as an aid in determining the intention of decedent, and evidence is admissible to support or rebut the presumption: McCadden’s Estate, 29 Dist. R. 214 (1920). If the evidence shows nothing more than a transfer of assets or a payment to or for a child the presumption applies and the transfer or payment would be considered an advancement or a satisfaction of a legacy. But if there is evidence which tends to rebut the presumption a question of fact arises as to what decedent really intended.

In the case of George O. Glessner, the evidence shows that when decedent made her will on July 27, 1926, directing that her estate be divided into three equal parts and giving one part to each of her three children, she was [275]*275residing with her sister, Mrs. Benner. Mrs. Benner died on September 3, 1932, and thereafter, on September 26, 1933, the property at 428 Anthwyn Road, Narberth, Pa., was purchased in the name of Anna L. Glessner, widow, and George O. Glessner, and the survivor of them and the heirs and assigns of such survivor. Pursuant to an agreement between decedent and George O. Glessner that if the son would provide a home the mother would supply the money to purchase the property, decedent paid the purchase price of $2,800 for the property which was subject to an existing mortgage of $8,000. Thereafter, in November 1936, she paid an additional sum of $2,000 on the principal of the mortgage, reducing the principal to $6,000 and making her total investment $4,800. After the house was purchased it was occupied by decedent, her son, and his wife and daughter, until decedent died on September 30, 1938. During this period George O. Glessner fulfilled his agreement by paying all the household expenses, taxes, and mortgage interest, and decedent had her living without cost to her.

On January 15, 1937, decedent’s other son, H. Hall T. Glessner, died. On March 10,1937, she added a codicil to her will by which she provided that out of his one-third share of her estate the sum of $50 should be paid to his widow, Mrs. Helen Glessner, and a similar sum to his stepson, Robert Glessner. The remainder of the share was to be divided: one third to George Glessner, one third to Florence Holt, and the remaining one third to her granddaughter, Mrs. Marion Pattison, daughter of Hall Glessner, and the present exceptant. No mention of the Narberth property was made in the codicil.

Exceptant contends that the sum of $4,800 invested by decedent in the Narberth property, which upon her death became the sole property of George O. Glessner, must be considered as a partial satisfaction of his legacy under the will. This contention overlooks the fact that decedent neither purchased the property for her son nor advanced the money to him to enable him to make the purchase. [276]*276The purchase was made in their joint names pursuant to the agreement for the support of decedent and, in return for her investment, decedent did receive support for five years. Moreover, by the arrangement she was protected in the event her son predeceased her, as in that event she would have been the sole owner of the property and her investment would have been intact. It is doubtful whether the son benefited by the arrangement in any respect other than the possibility of becoming the sole owner of the property if he survived his mother. In exchange for his occupancy of the house during her lifetime, he was compelled to pay the taxes, the mortgage interest, and the cost of maintaining the home.

In any event, the circumstance that the property was purchased pursuant to a proper contract for support would, in itself, rebut the presumption that the purchase money was intended as a satisfaction of a legacy. Moreover, no reference to the purchase of the property is made in the subsequently-executed codicil to the will by which the son’s share in his mother’s estate was increased. This, in itself, would not rebut the presumption against double portions: Miner et ux. v. Atherton’s Exec., supra; M’Kibbin’s Estate, supra; but it is a circumstance to be considered.

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Related

Alexander's Estate
83 Pa. Super. 210 (Superior Court of Pennsylvania, 1924)
Miner v. Atherton's
35 Pa. 528 (Supreme Court of Pennsylvania, 1860)
Weaver's Appeal
63 Pa. 309 (Supreme Court of Pennsylvania, 1870)
Eshleman's Appeal
74 Pa. 42 (Supreme Court of Pennsylvania, 1873)
Storey's Appeal
83 Pa. 89 (Supreme Court of Pennsylvania, 1877)
M'Kibbin's Estate
56 A. 62 (Supreme Court of Pennsylvania, 1903)
Appeal of Patterson
18 A. 430 (Philadelphia County Orphans' Court, 1889)

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Bluebook (online)
40 Pa. D. & C. 271, 1940 Pa. Dist. & Cnty. Dec. LEXIS 58, Counsel Stack Legal Research, https://law.counselstack.com/opinion/glessners-estate-paorphctmontgo-1940.