Kershow Estate

40 Pa. D. & C.2d 237, 1966 Pa. Dist. & Cnty. Dec. LEXIS 55
CourtPennsylvania Orphans' Court, Philadelphia County
DecidedSeptember 7, 1966
Docketno. 166
StatusPublished

This text of 40 Pa. D. & C.2d 237 (Kershow Estate) is published on Counsel Stack Legal Research, covering Pennsylvania Orphans' Court, Philadelphia County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kershow Estate, 40 Pa. D. & C.2d 237, 1966 Pa. Dist. & Cnty. Dec. LEXIS 55 (Pa. Super. Ct. 1966).

Opinion

Shoyer, J.,

— This trust arises under the will, a copy of which is hereto annexed, of J. Henry Kershow, who died March 17, 1918, whereby the testator gave two twenty-fifths of his residuary estate to his trustee, in trust, to pay the income to his cousin, Jennie Ketcham Quick, during her life, with “full right and power” in her to dispose of the remainder of the fund by her will, provided that if she did not leave a will disposing of this portion of his estate, then the principal thereof should “remain and become part of my residuary estate, and divided among the other persons herein mentioned and entitled to the same, in the same ratio, and under the same provisions as shall apply to each one of them respectively at the time of the death, under the above circumstances, of my said cousin”. Other portions of the residuary estate were given to the persons and to the several charities as reflected in the statement of proposed distribution. . . .

This account was filed because Jennie Ketcham Quick, later Owen, life tenant, died January 29, 1965. She left a will upon which letters testamentary were granted by the Surrogate of Hunterdon County, New Jersey, to Fidelity-Philadelphia Trust Company and George Edward Woodruff, executors. . . .

By her will, a copy of which is hereto annexed, Jennie K. Owen provided, in item ninth, a gift of her residuary estate, including:

“. . . all property over which I have any power of appointment, particularly under the Wills and Trusts of J. Henry Kershow and Carlton W. Kershow, which powers I hereby exercise in favor of this my residuary estate, I give, devise and bequeath to the FIDELITY PHILADELPHIA TRUST COMPANY and GEORGE EDWARD WOODRUFF, IN TRUST, NEVERTHELESS, for the following uses and purposes:
“To hold, manage, invest . . .. and,. . . pay over [239]*239and apply all of the net income to or for the benefit of my nephew, GEORGE EDWARD WOODRUFF, for and during the term of his natural life, and at his death, . . . the corpus of this trust . . . shall be paid, free of trust, as he may in his Last Will and Testament appoint, or in default or failure thereof, to my heirs and next of kin, as of the date of my death.” . . .

Validity of the Exercise of the Power of Appointment

By instrument dated October 29, 1951, executed by Jennie K. Owen, donee-life tenant, after referring to the power of appointment given her by the will of J. Henry Kershow, deceased, she in pertinent part provided :

“Intending to be legally bound, I hereby irrevocably release the right to exercise that power in favor of myself, my estate, my creditors or the creditors of my estate”.

Accountant, in its notice to the parties in interest and counsel for trustees appointed under item ninth of the will of Jennie K. Owen, deceased, take the position that donee’s partial release of her power of appointment did not prevent her from appointing her share of principal to the residuary legatees under her will, and that she effectively did so appoint the share of principal to her trustees for the benefit of her nephew, George Edward Woodruff, for life. We are now not concerned with the disposition of the remainder of the appointed share.

The validity and interpretation of the attempted exercise of the power is governed by the law of Pennsylvania, the domicile of the donor of the power, even though donee died domiciled in New Jersey: Windolph Trust, 374 Pa. 81 (1953); O’Reilly Estate, 371 Pa. 349 (1952); Barton Trust, 348 Pa. 279 (1944).

[240]*240In Barton Trust, supra, the court said, pages 281-82:

“In executing a power of appointment the donee disposes of the estate as that of the donor, the appointment being referred back to the instrument which created the power as if it had been actually embodied therein, . . . and it has been uniformly held that the proper and effective exercise of a power of appointment is, in the case of personalty, controlled by the law of the donor’s domicile at the time of the creation of the trust: [citations]”.

The power of appointment is releasable in whole or in part and may be released in such manner as to reduce or limit the persons or objects or classes of persons or objects in whose favor such power or interest would otherwise be exercisable: Estates Act of April 24, 1947, P. L. 100, sec. 3(a), as amended, 20 PS §301.3(a); Jeffers Estate, 394 Pa. 393, 396 (1959).

In a footnote in Jeffers Estate, supra, the Supreme Court noted, page 397:

“The law applicable to release of powers of appointment is completely influenced by federal tax considerations arising from the revisions of the Internal Revenue Code since 1942. Our Pennsylvania acts relative to release of powers of appointment sought to take advantage of the permitted federal tax benefits. See 5 Am. Law of Prop. §23.25 (1952)”.

See also Handy Trust, 5 D. & C. 2d 773, 775, 6 Fiduc. Rep. 385, 387, where Judge Bolger of this court observed: “It is well recognized that the release signed by the donee of the power was filed to comply with the provisions of the Federal tax law and was filed under the authority of the Estates Act of April 24, 1947, P. L. 100, 20 PS §301.3, or its predecessor, the Act of 1943, P. L. 797, as amended by the Act of 1945, P. L. 1337”.

And Mr. Bregy, in his treatise “Intestate, Wills and [241]*241Estates Acts of 1947”, has commented pointedly: “As most people apparently would rather avoid taxation than own a power, there was a general rush to release powers after the Revenue Act of 1942 became law”, (at page 5206). Especially was this true in reducing general powers to special powers. For this purpose, many draftsmen adopted the language of the Internal Revenue Code, 26 U.S.C.A. §811 (f), where a general power of appointment is defined as a power which is exercisable “in favor of the decedent [donee], his estate, his creditors or the creditors of his estate”. So in Handy Trust, supra.

In Windolph Trust, 374 Pa. 81 (1953), the court ruled, page 87:

“In determining whether a power of appointment was validly exercised and if so, its meaning, the Courts seek to ascertain the intent of the donee and this must be ascertained in precisely the same manner as a testator’s intent is discovered in a will: Lewis Estate, 349 Pa. 571, 37 A. 2d 482. This intent is ascertained and determined only from the meaning of the words used and not from what a Court or an advocate thinks the donee meant to say what he likely would have said if he had known the existing circumstances; the test is: What is the meaning of his words in the light of all the surrounding circumstances: [citations]

The “surrounding circumstances” here are, of course, the tax saving benefits provided by Congress to a donee who surrenders his general power of appointment in favor of a limited special power. There is no reason to believe that Jennie K. Owen, donee here, was motivated by any other purpose when she executed the release in 1951. Of significance is the admission by counsel for the opposing charity that such was the purpose of her release.

Furthermore, since the Estates Act (section 3) is [242]*242in pari materia with the Act of Congress of 1942 and its amendments, these two laws should be construed together: Statutory Construction Act of May 28, 1937, P. L. 1019, sec. 62, 46 PS §562.

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Related

Jeffers Estate
147 A.2d 402 (Supreme Court of Pennsylvania, 1959)
O'Reilly Estate
89 A.2d 513 (Supreme Court of Pennsylvania, 1952)
Grier Estate
170 A.2d 545 (Supreme Court of Pennsylvania, 1961)
Barton Trust
35 A.2d 266 (Supreme Court of Pennsylvania, 1943)
Lewis Estate
37 A.2d 482 (Supreme Court of Pennsylvania, 1944)
Shipley's Estate (No. 2)
12 A.2d 347 (Supreme Court of Pennsylvania, 1940)
Wood's Estate
57 A. 1103 (Supreme Court of Pennsylvania, 1904)
Windolph Trust
97 A.2d 67 (Supreme Court of Pennsylvania, 1953)

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Bluebook (online)
40 Pa. D. & C.2d 237, 1966 Pa. Dist. & Cnty. Dec. LEXIS 55, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kershow-estate-paorphctphilad-1966.