In re Estate of Eck

179 N.E.2d 192, 87 Ohio Law. Abs. 65, 21 Ohio Op. 2d 154, 1960 Ohio Misc. LEXIS 195
CourtMontgomery County Probate Court
DecidedDecember 16, 1960
DocketNo. 146744
StatusPublished

This text of 179 N.E.2d 192 (In re Estate of Eck) is published on Counsel Stack Legal Research, covering Montgomery County Probate Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Estate of Eck, 179 N.E.2d 192, 87 Ohio Law. Abs. 65, 21 Ohio Op. 2d 154, 1960 Ohio Misc. LEXIS 195 (Ohio Super. Ct. 1960).

Opinion

Zimmers, J.

This cause is before the Court upon exceptions filed by Charlotte L. Eck, executrix of the last will and testament of Ida Pausing Eck, Deceased, to the Court’s determination of the inheritance tax payable on successions arising by reason of the death of Ida Pansing Eck. The decedent died June 12, 1958, at the age of eighty-four.

The exceptor alleges that the Court errored in finding that the shares of stock of the American Envelope Company set forth in Schedule D of the application for determination of. inheritance tax was made in contemplation of death and subject to inheritance tax for the reason that said transfer was a free and unconditional gift by mother to her daughters and not made [68]*68in contemplation of death, and therefore, not subject to inheritance tax.

The only evidence introduced in the trial was introduced by the exceptor. The Tax Commissioner introduced no evidence of any nature whatsoever.

There is no question that the decedent made the alleged gift to her three daughters within two years preceeding the date of donor’s death and were without a valuable consideration. Therefore, the burden was upon the exceptor to prove that the gifts were not made in contemplation of death and to overcome the presumption made by the statutes.

The Court must decide whether the gifts, totalling eighty-five thousand, eight hundred dollars, made by the decedent to her three daughters constituted gifts in contemplation of death.

Section 5731.02, Revised Code, provides that a tax be

“. . . levied upon the succession to any property passing, in trust or otherwise, to or for the use of a person, ... in the following cases:

“(1) In contemplation of the death of the grantor, . . . or donor; . . .”

Section 5731.04, Revised Code, provides that

“Any transfer of property . . . without valuable consideration . . ., if so made within two years prior to the death of the transferror, is deemed made in contemplation of death . . . unless the contrary is shown ...”

The definition for the term “contemplation of death” in Section 5731.01, Revised Code, is as follows:

“(E) ‘Contemplation of death’ means that expectation of death which actuates the mind of a person on the execution of his will.”

This definition leaves much to be desired. Many authorities in other states have defined “contemplation of death” as the fear of impending death arising from some physical condition or peril in contrast to the general expectation of eventual death which is contemplated by all rational persons. See Tax Commission v. Parker, 117 Ohio St., 215 (1927), discussing the law of New York; 28 Am.Jur., Inheritance, Estate, and Gift Taxes, Sec. 145, page 83; 85 C. J. S., Sec. 1147 (2) (b), page 917.

[69]*69Our Supreme Court, in Syllabus Pour of Tax Commission v. Parker, supra, bas placed upon this phrase a broader connotation than the courts of other states. It has held that the determining factor is whether such gift was in the nature of a distribution of the decedent’s property in contrast to whether it was one which was merely intended as a lifetime favor or Robinson, 145 Ohio St., 55, 30 Ohio Opinions, 280 (1945); Hildebrant’s Estate v. Department of Taxation, 86 Ohio App., 246, 41 Ohio Opinions 160 (1949); Schaefer v. Department of Taxation, 75 Ohio App., 533, 31 Ohio Opinions, 313 (1945); In re Estate of Bender, 60 Ohio App., 107, 13 Ohio Opinions 215 (1938); In re Estate of Perkins, 2 Ohio Supp., 33 (1938).

If the purpose of the transfer was a distribution of the donor’s property in substitution for a testamentary disposition merely to hasten the effects of what would otherwise be testamentary or similar disposition, then the transfer is taxable.

Where a gift has been made within two years of death, the burden of proof to show by a preponderance of the evidence that such gift was not in contemplation of death is upon the person making the claim. In re Walker’s Estate, 161 Ohio St., 564 (1954).

Under Section 5731.01, Revised Code, a rebuttable presumption is set up that the transfer was taxable if a decedent died within a two year period after the transfer. There can be no question that the presumption is established in the case at bar, but this rebuttable presumption serves to shift the burden of proof to the exceptor to satisfy the Court by a preponderance of the evidence that the said transfer was not made to avoid taxes and was not within the meaning of Section 5731.01, Revised Code, which defines “contemplation of death means that expectation of death which actuates the mind of a person on the execution of his will.”

The exceptors, in their briefs, have very comprehensively considered cases involving transfers within two years of death and transfers made more than two years prior to death.

The Attorney General asserts .in his brief that the “factual considerations” in the cases involving gifts made more than two years before death “would be of little value as guides.” The Court readily agrees. Each case must be decided upon its [70]*70own particular facts. However, there is a distinction between the two types of cases, but it is procedural rather than substantive. The essential distinction lies only in matters of presumption and burden of proof. Regardless of where the burden of proof lies or who is aided by the presumption, certain factual considerations have probative weight in the ascertainment of the donor’s state of mind when the gifts were made. These factual considerations are all probative to determine whether the donor had “that expectation of death which actuates the mind of a person on the execution of his will.” See Section 5731.01 (E), Revised Code.

It is entirely proper to consider such facts as the donor’s age, health, previous practice as to gifts, contemporaneous execution of the donor’s will and transfer of his property, whether the gift is referable to the donees’ intestate share or to the portion the donees are to receive through the donor’s will, the portion of the donor’s estate transferred, the length of time between the time the gifts were made and death, and other pertinent circumstances in the consideration of whether the donor’s motives in making the transfer were to effect a distribution of his property or to effect an act of generosity. 85 C. J. S., Sec. 1147 (2) (d), page 924; also see Hildebrant’s Estate v. Department of Taxation, supra; 148 A. L. R., 1052; 28 Am. Jur., Inheritance, Estate, and Gift Taxes, Sec. 149, 150, 151, page 85.

The Court will now consider these factors in the light of the facts disclosed by the testimony in the case at bar:

1. Age. Decedent was eightv-two years of age at the time of the transfer of eleven hundred shares of common stock of the American Envelope Company to each of her three daughters: Christine Eck Rees, Dorothy Eck Bierley, and the exceptor, Charlotte L. Eck — the decedent’s only heirs-at-law. The Attorney General in his brief places much emphasis on the age of the decedent. Age must be considered a factor with other facts and circumstances at the time the gift was made. However, age is not conclusive or fully determinative and decisive of the question at bar. The testimony showed that the decedent was an intelligent person and was mentally alert up to the time of her death. She knew at the time of making the gifts that she had

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Related

Schaefer, Exr. v. Dept. of Taxation
62 N.E.2d 374 (Ohio Court of Appeals, 1945)
In Matter of Estate of Bender
19 N.E.2d 781 (Ohio Court of Appeals, 1938)
Hildebrandt v. Department of Taxation
86 N.E.2d 802 (Ohio Court of Appeals, 1949)
Tax Commission v. Parker
158 N.E. 89 (Ohio Supreme Court, 1927)
In Re Estate of Thompson
68 N.E.2d 71 (Ohio Supreme Court, 1946)
Estate of Kraus v. Department of Taxation
60 N.E.2d 615 (Ohio Supreme Court, 1945)

Cite This Page — Counsel Stack

Bluebook (online)
179 N.E.2d 192, 87 Ohio Law. Abs. 65, 21 Ohio Op. 2d 154, 1960 Ohio Misc. LEXIS 195, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-estate-of-eck-ohprobctmontgom-1960.