Matter of Estate of Palmer

708 P.2d 242, 218 Mont. 285, 1985 Mont. LEXIS 918
CourtMontana Supreme Court
DecidedOctober 21, 1985
Docket84-167
StatusPublished
Cited by6 cases

This text of 708 P.2d 242 (Matter of Estate of Palmer) is published on Counsel Stack Legal Research, covering Montana Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Matter of Estate of Palmer, 708 P.2d 242, 218 Mont. 285, 1985 Mont. LEXIS 918 (Mo. 1985).

Opinions

MR. JUSTICE WEBER

delivered the Opinion of the Court.

A motion to determine the existence of a joint tenancy was filed in the probate proceedings in the District Court of Park County. An appeal was taken from the order determining that the checking account, cattle, cattle brands and brokerage account did not pass to the surviving partner in his capacity as surviving joint tenant. We affirm the District Court:

The issues are:

1. Did the District Court err in holding that the bank checking account in the names of William Palmer and Robert Palmer as joint tenants was partnership property?

2. Did the District Court err in holding that the cattle branded with a brand registered in the names of “William Palmer or Robert Palmer” were partnership property?

3. Did the District Court err in holding that a brokerage account, registered in the name of William Palmer for which Robert Palmer signed a document as a joint tenant, was partnership property?

Following are pertinent facts contained in the uncontested findings of fact of the District Court.

Robert Palmer (Robert) died on November 8, 1981. For many years prior to Robert’s death, he and his brother, William, operated and conducted a partnership called “Palmer Brothers.” The partnership was engaged in the business of raising livestock and feed, conducting a feedlot operation, and buying and selling cattle on ran[287]*287chlands about 10 miles northeast of Livingston in Park County, Montana. William and Mildred, his wife, resided on the ranch for many years prior to Robert’s death, while Robert resided in Livingston. Robert married Constance on September 21, 1979, and Constance is Robert’s sole heir at law. For many years prior to Robert’s death, Robert and William owned a checking account in First Bank Livingston, in which they deposited all receipts and the proceeds from cattle sales and other income, and from which they paid all partnership debts and obligations. Additional facts will be set forth in our discussion of the checking account issue. William and Brad Palmer, son of William, claimed the proceeds in the checking account at the time of Robert’s death as surviving joint tenants. Constance contends that the balance is a part of the partnership assets and should be accounted for in the partnership. Because of the or brand certificate, William claims that the brands and any cattle carrying them passed to him as surviving joint tenant, and to Mildred as his successor in interest. Constance claims the property is part of the partnership’s assets and should be accounted for in the partnership. In 1979, William opened a commodity or brokerage account with Merrill Lynch. William claims the Merrill Lynch account as his sole property, or as surviving joint tenant if the account is found to be joint, while Constance claims the account is part of the partnership assets.

The District Court pointed out that William testified that his relationship with Robert was very close and they got along well both as friends and as business partners until the last few years of Robert’s life, when his personality changed and he did erratic things. Constance testified that Robert and William were not friendly for several years before Robert’s death, although she acknowledged that Robert named William as personal representative in his 1977 will. Another brother, Maro Palmer, testified that Robert had told him William was trying to take the business away from him and that Robert’s behavior had not changed until a few weeks before death. Brad Palmer testified that William and Robert got along well with only normal disagreements until the last year or so when Robert became unable to make decisions and lost his judgment. A neighboring rancher testified that the brothers got along well and he never saw any disagreement.

The District Court found that the partnership income tax returns for 1972 through 1981, with 1974 missing, showed that the partnership paid all of the expenses of operating the ranch, including huge [288]*288sums for purchasing and feeding livestock, interest on loans, taxes, vet care and trucking, from the Palmer Brothers’ checking account; that all partnership income, including profits from cattle sales, was deposited in that account; and that the partners split equally any net profits or losses. The District Court further found that neither brother had any individual source of income.

The evidence established that the bank account was opened in joint tenancy form in 1947, and the Palmer Brothers’ partnership commenced business in 1949.

Following Robert’s death on November 8, 1981, Brad Palmer was appointed as personal representative of his estate under Robert’s will of February 7, 1977. Constance, as sole heir of Robert, petitioned the court to terminate the appointment of Brad as personal representative. She was appointed as personal representative of the estate of Robert on February 24, 1982, and continued in that capacity. William filed a petition to determine joint tenancies in the probate proceeding. A hearing was held, testimony was submitted and evidence was introduced by both sides. By Order Ruling on Motion dated March 7, 1984, the District Court denied the motion of William to determine the checking account, cattle, cattle brands and brokerage accounts passed to him as surviving joint tenant. The court further determined that all of such items of personal property were the partnership property of Palmer Brothers and were to be accounted for by William as surviving partner, or his successors, to Constance, the personal representative of Robert’s estate. William and Mildred, his wife and successor, appealed from the Order.

I

The issues presented require us to consider the provisions of the Uniform Partnership Act as adopted in 1947. Because there are few Montana cases which constitute authority on the legal issues before us, we have found it necessary to review the historical background of partnerships and partnership property.

John Collyer’s A Practical Treatise on the Law of Partnership, originally published in England in 1832, contains an illuminating discussion of the history of the law of partnership which was well developed by cases in both England and the United States by 1830. Based upon a number of English and American cases cited in the footnotes, the treatise discusses the treatment of partnership property upon the death of one partner. The analysis is a clear forecast [289]*289of the Uniform Partnership Act approach as developed almost 100 years later:

“From what has been already observed as to the want of survivor-ship among partners, it follows, that, upon the decease of one of several partners, his share of the movable stock and effects of the partnership, subject to the partnership debts, devolves to his personal representatives, who thereupon become, both at law and in equity, tenants in common with the surviving partners. Although, for the purpose of encouraging trade, it is held that the harsh doctrine of the jus accrescendi,

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Matter of Estate of Palmer
708 P.2d 242 (Montana Supreme Court, 1985)

Cite This Page — Counsel Stack

Bluebook (online)
708 P.2d 242, 218 Mont. 285, 1985 Mont. LEXIS 918, Counsel Stack Legal Research, https://law.counselstack.com/opinion/matter-of-estate-of-palmer-mont-1985.