In re Estate of Jennings

40 Ohio Law. Abs. 313, 28 Ohio Op. 66, 1944 Ohio Misc. LEXIS 186
CourtCuyahoga County Probate Court
DecidedFebruary 21, 1944
DocketNo. 294047
StatusPublished

This text of 40 Ohio Law. Abs. 313 (In re Estate of Jennings) is published on Counsel Stack Legal Research, covering Cuyahoga 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 Jennings, 40 Ohio Law. Abs. 313, 28 Ohio Op. 66, 1944 Ohio Misc. LEXIS 186 (Ohio Super. Ct. 1944).

Opinion

[314]*314OPINION

By BREWER, J.

Gilbert P. Jennings died testate on.April 17, 1941, and The National City Bank of Cleveland was appointed executor of said decedent’s will on May 2, 1941. Thereafter, on August 1st, 1941, the executor filed an application for determination of the inheritance tax payable on the successions to said estate and the tax thereon was duly determined and paid.

The said Gilbert P. Jennings, during his lifetime, made several gifts to various organizations, and these gifts were listed in the supplemental application for determination of the inheritance tax, if any, payable thereon, which was filed in this Court on February 15th, 1943. The beneficiaries of these gifts and the tax assessed on each, are as follows:

Sisters of St. Joseph $ 700.00

Holy Cross College 182.00

St. Agnes Church 1456.00

Society of The Divine Word 140.00

Province of the Immaculate Conception 70.00

Marianhill Mission Society 70.00

St. Mary’s Seminary 70.00

Servite Fathers 70.00

Missionary Servants of The Most Holy Trinity 70.00

The Catholic Church Extension Society 700.00

Seminary of Our Lady of The Lake 72.80

The Court assessed the tax on these gifts as transfers made in contemplation of death. In the order determining the tax the executor was ordered to pay the tax, as will appear from the following quotation:

“The Court further finds that the persons entitled to succeed to said estate, their ages when material, their relationship, if any, to the decedent, the value of the succession to which each is entitled; the exemption allowed each, the balance of each succession subject to the tax, the amount of the tax to which each is liable, the person by whom such tax should be paid, and the township or municipality in which such tax originates are as follows: * * *

Persons by Whom Tax Should be Paid

The National City Bank of Cleveland, Extr.

J. H. O’Connor, Trust Officer,

Cleveland, Ohio.”

[315]*315The executor filed exceptions to the determination of the tax. The exceptor bases its exceptions on the grounds that none of the donees of said gifts is a beneficiary under the decedent’s will, and that the executor at no time had in its possession, or under its control, any funds, property, or any assets of any kind whatsoever belonging to the donees; that the Court, neverthless, found that the exceptor, The National City Bank of Cleveland, as executor of the will of the said Gilbert P. Jennings, deceased, was the person by whom all of the aforementioned taxes’ should be paid, and failed to find that each of the donees should pay the tax assessed against its succession and that such assessment of the tax was erroneous; that none of the taxes which were determined to be payable on the successions listed in said supplemental application are payable by or should be paid by the exceptor; and that said executor is not liable therefor; that the liability for payment of the taxes rests upon each and every transferee, to the extent of the tax assessed on the succession which passed to him; and that the order of February 15th, 1943, should be amended by striking out therefrom, the name of The National City Bank, executor, as the person by whom the tax should be paid, and substituting therefor the names of the transferees who received the gifts as the persons liable for the tax and by whom it should be paid.

The issues raised by these exceptions are: In the determination of the inheritance tax in an estate in which part of tlie successions consists of gifts or transfers of property made by the decedent prior to death, is the executor personally liable for the payment of the tax; and: Is the executor authorized to pay taxes assessed against transfers made in contemplation of death out of the residuum of the estate?

Under §5336 GC, it is the duty of the executor to pay the inheritance taxes. It says:

“Such taxes shall be and remain a lien upon the property passing until paid, and the successor and executors or administrators of the general estate of the decedent, and the trustees of such property shall be personally liable for all such taxes, with interest as hereinafter provided, until they shall have been paid as hereinafter directed.”

The executor contends that the statute obligates the executor to deduct the amount of the inheritance tax assessed [316]*316against the succession of a beneficiary from any funds or property in his possession belonging to the beneficiary, and that the executor is personally liable only to the extent that he makes distribution without deducting the tax. This appears to be a just and reasonable construction of the statute, for the reason that it is not likely that the statute intends that the executor should ever pay the inheriance taxes out of his own property, except in case he fail to deduct the taxes before paying over the legacy to the beneficiary.

The exceptor cites as to the prevailing rule of law in respect to the personal liability of the executor or administrator in the payment of inheritance taxes, where the fiduciary never had possession of the property, which is the subject of the succession, and where there is no statute applicable, the statement made in 128 A. L. R. 125, which is:

“Where an executor, administrator or trustee never had possession of the property constituting a legacy, devise, or other distributive share of the decedent’s estate, it has been held in the majority of cases that such legal representative was not personally liable for the succession tax thereon.”

There is, however, an exception to this principle where other property passing to the same beneficiary is available to the executor to reimburse himself for the tax, in which case he has been held liable for this- payment.

In Wellman v Trust Company, 107 Oh St 267, the Supreme Court, in construing the provisions of the inheritance tax law on page 275 said this:

“These various provisions would warrant the construction that both the primary and ultimate liability to pay the taxes was upon the respective beneficiaries, and that the liability imposed upon the administrator, executor or trustee was imposed for the purpose of insuring his performance of his duty in the collection of the tax from the. various beneficiaries, and could the act be made to work in such a way as to secure payment of the taxes by the beneficiary forthwith out of the property passing, we would hold to such effect.”

It was held by the Supreme Court of Ohio in the case of Wonderly v Tax Commission, 112 Oh St 233, that the inheritance tax statutes of Ohio were probably modeled after the [317]*317New York Transfer Tax Law which was in effect prior to September 1st, 1930. Therefore, the construction of the New York law just mentioned by the courts of New York should-be very helpful in construing similar provisions of the Ohio law. Among the provisions contained in the old New York law on which the Ohio statutes are based, is one which requires the executor to obtain a receipt evidencing payment of the tax. This provides:

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Related

In Re Powell's Estate
101 P.2d 54 (Montana Supreme Court, 1940)
In Re Deutz
149 A. 257 (New Jersey Superior Court App Division, 1930)
Matter of Meyer
103 N.E. 713 (New York Court of Appeals, 1913)

Cite This Page — Counsel Stack

Bluebook (online)
40 Ohio Law. Abs. 313, 28 Ohio Op. 66, 1944 Ohio Misc. LEXIS 186, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-estate-of-jennings-ohprobctcuyahog-1944.