Jennings Estate

19 Pa. D. & C.2d 240, 1959 Pa. Dist. & Cnty. Dec. LEXIS 123
CourtYork County Orphans' Court
DecidedFebruary 24, 1959
StatusPublished

This text of 19 Pa. D. & C.2d 240 (Jennings Estate) is published on Counsel Stack Legal Research, covering York County Orphans' Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jennings Estate, 19 Pa. D. & C.2d 240, 1959 Pa. Dist. & Cnty. Dec. LEXIS 123 (Pa. Super. Ct. 1959).

Opinion

Kohler, P. J.,

At the audit of the first and final account of George Hay Kain, Jr., and William H. Kain, executors of the Will of Catherine L. Jennings, late of West Manchester Township, York County, deceased, held on February 4, 1959 and finally closed on February 11, 1959, a claim was presented by the Commonwealth of Pennsylvania, Department of Revenue through its counsel, Nevin Stetler, Esq., in the amount of $616.36, with interest, representing the alleged balance of transfer inheritance tax due on the value of the life estate of decedent bequeathed to her under the will of her deceased husband, Herbert V. Jennings, who died, July 23, 1957, just 12 days prior to the death of Catherine L. Jennings. The executors of the latter objected to the claim and its validity was argued February 11, 1959. All pertinent facts are matters of record in this court.

The will of Herbert V. Jennings bequeathed his residuary estate to York Trust Company, in trust, to hold, invest and reinvest the same, and:

“(a) To pay the income therefrom, together with so much of the corpus or principal thereof as my Trustee in the exercise of its sole and uncontrolled discretion may deem proper to, or for the comfort, maintenance and support of, my wife, Catherine L. Jennings, for and during the term of her natural life,” and there then follows, upon the death of the widow, a succeeding life estate for testator’s step-daughter with a remainder, freed of trusts, to testator’s next of kin under the intestate laws.

The will contained no direction concerning the payment of inheritance taxes.

Catherine L. Jennings died August 5, 1957, surviving the testator by only 12 days.

On July 31, 1958, the Commonwealth’s appraiser filed an appraisement of Catherine’s life estate based upon her life expectancy of 7.034 years at age 66 and [242]*242in our adjudication of the executor’s final account in the estate of Herbert V. Jennings we ascertained the value of her life estate, based upon this appraisement, to be the sum of $34,852.50 and found the tax due thereon at two percent to be $687.05.

The life estate was equitable, not legal, and consisted entirely of the income from stocks, bonds, mortgages and cash, with the sole exception of some valueless old coins and jewelry inventoried at $1.

During the 12 days duration of the life estate, the net income therefrom apportionable to the life tenant was only the sum of $70.69, or less than the tax assessed by $616.36.

At the audit of the Herbert V. Jennings estate, the Comonwealth presented its claim for the full amount of the tax assessed. We allowed the claim against that estate only to the extent of the income collected for the life tenant, to wit $70.69. In so doing, we adopted the reasoning in Loomis’ Estate, 61 D. & C. 626, that in the absence of any testamentary provisions relating to the payment of transfer inheritance taxes, the estate of a decedent is not liable for such taxes assessed against a life estate in excess of the amount actually distributable as income to the estate of the life tenant who died shortly after the original decedent, since the general law is well established that when there is no direction in the will to the contrary the tax upon a life estate is payable only from the life tenant’s income: Crane’s Estate, 314 Pa. 193; Brown’s Estate, 208 Pa. 161; Penn-Gaskell’s Estate (No. 1), 208 Pa. 342. See also Tomlinson Estate, 48 Lanc. 289.

The Commonwealth now presents its claim for the unpaid balance of the tax, namely $616.36, against the estate of Catherine L. Jennings, the deceased life tenant.

It would appear that the appraisement of the life estate, made after the death of the life tenant, was [243]*243correctly made according to the life expectancy as of the date of the husband’s death and that an appeal therefrom would have been of no avail: Reynolds Estate, 359 Pa. 616; Rowell’s Estate, 315 Pa. 181.

The issue now turns upon the nature and extent of the liability, if any, of a distributee for the payment of transfer inheritance taxes upon his inheritance.

The statute imposing the tax is the Transfer Inheritance Tax Act of June 20, 1919, P. L. 521, as amended, 72 PS §2301 et seq. The act does not, expressly and in so many words, spell out personal liability of the inheritor of property.

In Cullen Estate, 142 Pa. 18, arising under the prior Act of May 6, 1887, P. L. 79, the personal liability of devisees of realty was recognized by the Supreme Court.

In Bute Estate, 355 Pa. 170, Mr. Justice Stearne, citing Cullen Estate, supra, states that under the present Act of 1919, the heir or beneficiary is personally liable for the amount of the tax.

In Brooks Estate, 2 D. & C. 2d 256, decedent had been devised realty by her deceased brother. It had been awarded to her subject to the inheritance tax but which tax she did not pay. The tax was paid after her death and it was held that her devisees were freed of the burden of the tax and were entitled to exoneration from decedent’s personal estate. In reaching his conclusion of personal liability, Judge Hunter points out that the act imposes a tax upon inter vivos transfers made in contemplation of death and that the legislature has used practically the same language with respect to the imposition and collection of the tax on such gifts as it has used with respect to transfers by will or under the intestate laws. If no liability for the tax was intended by the Legislature, the Commonwealth would be without power or authority to collect the tax upon inter vivos transfers. We may [244]*244add that an identical situation exists with respect to the assessment and collection of such taxes on joint property having the right of survivorship. The liability of the survivor for the tax is settled. See Cochrane’s Estate, 842 Pa. 108.

We recognize the general principle of personal liability established by the foregoing cases but we question its binding application to the facts here present, where the tax itself is more than nine times the award to the inheritor. We believe that when the legislature fails to impose personal liability in absolute and express terms we have the power to declare circumstances under which such liability is not to be inferred.

It has been stated that under the Act of 1919, supra, the tax imposed is not on the transfer to the inheritor but is a tax on the succession or right of inheritance, and that it is essentially an excise tax on the privilege of inheritance and not a tax on property: Tack’s Estate, 325 Pa. 545. It is not assessed against the estate of decedent but against the legatees and devisees, as what is taxed is the right of succession or the privilege of receiving the property possessed by decedent, the plain intent of the statute being to charge the beneficiary: Youngblood’s Estate, 117 Pa. Superior Ct. 550.

The Act of 1919, supra, gives many remedies against the property, such as a lien on real estate, and makes it the duty of a fiduciary who has the property in his hands to deduct and pay the tax from the distributive share.

“Normally the life tenant pays his tax from installments of income received in his lifetime”: Crane’s Estate, supra, p. 199. However, where the life tenant’s right to income ceases by virtue of his death, that source of payment is immediately terminated.

[245]*245Catherine L.

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Bluebook (online)
19 Pa. D. & C.2d 240, 1959 Pa. Dist. & Cnty. Dec. LEXIS 123, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jennings-estate-paorphctyork-1959.