In Re H. And C.S. Living Trust, Michelle Vittitow, V. Axel Strakeljahn

CourtCourt of Appeals of Washington
DecidedJuly 8, 2024
Docket86027-5
StatusUnpublished

This text of In Re H. And C.S. Living Trust, Michelle Vittitow, V. Axel Strakeljahn (In Re H. And C.S. Living Trust, Michelle Vittitow, V. Axel Strakeljahn) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re H. And C.S. Living Trust, Michelle Vittitow, V. Axel Strakeljahn, (Wash. Ct. App. 2024).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

IN THE MATTER OF THE H. AND C.S. LIVING TRUST, No. 86027-5-I

MICHELLE VITTITOW, DIVISION ONE

Respondent, UNPUBLISHED OPINION

v.

AXEL STRAKELJAHN, individually, and Trustee of the H. and C.S. Living Trust, and SKYFALL 69, LLC, a Washington limited liability company,

Appellants.

CHUNG, J. — Heinz Strakeljahn and his wife created a trust containing all

their community property. After his wife’s death, he executed a disclaimer of her

share of community property and gifted real property out of the trust to his son.

After the father’s death, his daughter filed a petition under the Trust and Estate

Dispute Resolution Act (TEDRA), chapter 11.96A RCW, claiming that the gift was

invalid under the terms of the trust and the father’s disclaimer of property. The

trial court agreed, determined the gift was invalid, and revoked the deed. We

conclude the trust instrument allowed the distribution of the real property, and the

gift was proper. Accordingly, we reverse the order revoking the deed and

granting attorney fees to the daughter. No. 86027-5-I/2

FACTS Heinz and Christa Strakeljahn had two children, Axel and Michelle. 1 Heinz

and Christa signed a community property agreement declaring all of their assets

to be community property. As part of their estate planning, they established the

H. and C.S. Living Trust. Heinz and Christa served as co-Trustees, and

subsequently amended the Trust Agreement solely to add Axel as co-Trustee.

Heinz and Christa funded the Trust with both real and personal property

for the stated purpose of providing for their health, support, and maintenance.

They deeded their real property—consisting of an apartment building in Tacoma,

their primary residence and a vacant lot in Kent, and an apartment building in

Burien—to the Living Trust. All assets of the Trust retained their character as

community property, and any property transferred into the Trust during the joint

lives of the Grantors would be deemed community property. The Grantors could

revoke or amend the Trust during their joint lifetime.

The Trust Agreement provides that following the death of one of the

Grantors:

The entire beneficial interest in the Trust assets shall pass to the surveying [sic] Grantor and be held in the original Trust as the “Marital Trust,” unless and to the extent that the surviving Grantor, as beneficiary, disclaims all or any portion of the Trust that is then considered to be a part of the deceased Grantor’s estate. In such event, the disclaimed assets, which may be dissimilar in kind, but equal in value to the extent of the disclaimer, shall be transferred to the Shelter Trust and held and administered pursuant to the Shelter Trust terms herein.

1 Michelle’s last name is Vittitow. Due to the other family members’ shared last name, to

avoid confusion, we refer to the individuals by their first names. We intend no disrespect.

2 No. 86027-5-I/3

The assets in the Marital Trust would remain subject to the surviving

Grantor’s powers to amend or revoke. The Shelter Trust would be “neither

amendable nor revocable by the surviving Grantor,” and would consist of assets

allocated by the Trustee pursuant to the disclaimer. The purpose of the Shelter

Trust “shall be to provide for the surviving Grantor’s health, support and

maintenance to the extent that it has distributable income.” The Trustee has no

power or authority to distribute Shelter Trust assets in excess of Trust income,

except under an annual “five and five power” which allows the Beneficiary to

withdraw the greater of five percent of the principal or $5,000. Upon the death of

the surviving Grantor, the Trustee was to administer specific distributions for

individuals including grandchildren and then distribute the Trust assets in two

equal portions to Axel and Michelle or to their next of kin.

Christa died in August 2019. At the time of her death, the Trust held

assets worth around $5 million, including the real property Heinz and Christa had

previously deeded to the Trust. Maurie Laufer, Heinz and Christa’s longtime

accountant, advised Heinz to disclaim up to $2,193,000 to the Shelter Trust in

order to maximize the amount of Christa’s estate that would pass tax-free upon

his death. On December 5, 2019, Heinz executed a “disclaimer of interest,”

declaring:

I, HEINZ STRAKELJAHN, a beneficiary under the Amended and Restated H. and C.S. Living Trust, originally dated July 11, 2016, (the “Trust”) hereby disclaim, renounce and refuse to accept all rights, title, benefits and interest in that portion of the Trust assets that is part of the Estate of Christa Strakeljahn and to any interest I might have or acquire in said real property assets so that the disclaimed assets may be transferred to the “Shelter Trust” as provided for in the Trust.

3 No. 86027-5-I/4

This disclaimer was signed by Heinz individually, as well as by Heinz as Trustee

and Axel as an individual. Heinz executed an identical version of this disclaimer

again on February 14, 2020, except this version had an additional signatory, the

attorney for the Trust.

In January and early February 2020, Heinz told Laufer that he wanted to

revisit his estate planning documents so that Axel would receive 2/3 of the estate

and Michelle would receive 1/3, rather than 50/50, because Axel had been

managing all of the investment properties and deserved more of the estate.

Specifically, Heinz wanted Axel to have the Tacoma apartment building. Laufer

recommended a non-pro rata allocation of the disclaimed assets to fund the

Shelter Trust by moving 100 percent of the Burien apartment building and some

of the cash assets into the Shelter Trust, so that a total of not more than

$2,193,000 would pass to the Shelter Trust, thereby minimizing estate taxes due

at Heinz’s death. Laufer prepared a new estate distribution proposal to this effect.

In May 2020, Heinz hired attorney Karol Whealdon 2 to fund the Shelter

Trust and revise his estate plan in keeping with his wishes. Laufer and Whealdon

advised Heinz that he could gift the Tacoma apartments to Axel during his life,

which would further reduce estate tax. Whealdon drafted a deed to execute the

gift of the Tacoma apartments to Axel and a deed to transfer the Burien

apartments to the Shelter Trust. Heinz and Axel, as co-Trustees of the Living

Trust “and pursuant to a disclaimer of interest executed by Heinz Strakeljahn

dated February 14, 2020,” signed a Trustee’s deed transferring the Burien

2 Formerly Karol Whealdon-Andrews.

4 No. 86027-5-I/5

apartments to the Shelter Trust. Heinz alone, as Grantor of the Marital Trust,

signed a Trustee’s deed granting the Tacoma apartments to Axel’s LLC, Skyfall

69. Axel filed a real estate excise tax supplemental statement stating that he

accepted the gift and would assume payment of the debt on the property. Heinz

filed a gift tax return to report the gift.

Heinz died on April 27, 2022. In September, an attorney contacted Axel on

behalf of Michelle, questioning the gifting of the Tacoma apartments during

Heinz’s lifetime. Axel’s attorney responded that the Tacoma apartment was not

an asset of the Trust and that Heinz had gifted the property from the Marital Trust

as the surviving Grantor.

In July 2023, Michelle filed a TEDRA petition, requesting an order

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Cite This Page — Counsel Stack

Bluebook (online)
In Re H. And C.S. Living Trust, Michelle Vittitow, V. Axel Strakeljahn, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-h-and-cs-living-trust-michelle-vittitow-v-axel-strakeljahn-washctapp-2024.