Williams Estate

42 Pa. D. & C.2d 169, 1967 Pa. Dist. & Cnty. Dec. LEXIS 121
CourtPennsylvania Orphans' Court, Philadelphia County
DecidedMarch 23, 1967
Docketno. 2481 of 1966
StatusPublished

This text of 42 Pa. D. & C.2d 169 (Williams 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
Williams Estate, 42 Pa. D. & C.2d 169, 1967 Pa. Dist. & Cnty. Dec. LEXIS 121 (Pa. Super. Ct. 1967).

Opinion

Shoyer, J.,

Decedent, Joseph L. Williams, also known as Joseph Leroy Williams and Joseph L. Williams, M. D., died July 1, 1965, survived by his spouse, Carrie W. Williams, and leaving a will and codicil, a copy of each of which is hereto annexed, whereby he gave his entire estate to his widow, Carrie, absolutely, with alternative disposition in the event she should predecease him, not necessary to recite, since she is living.

Letters testamentary were granted by the register of wills on July 15, 1965, to Carrie W. Williams, accountant, and proof of publication of the grant of same is hereto annexed.

Payment of Pennsylvania estate tax on June 8, 1966, in the sum of $66.42, was duly vouched.

Charles F. Nahill, Esq., Special Assistant Attorney General, and Albert Bartolomeo, Esq., appeared for the Commonwealth of Pennsylvania claiming transfer inheritance tax, and the awards will be made subject thereto.

The statement of proposed distribution and notice of the audit recite that the only questions requiring adjudication arise from the “failure of the Pennsylvania Revenue Dept, to allow as deductions from gross estate for determination of Pennsylvania Inheritance Tax”:

“1. The sum of $3,746.49 as the balance due as of the date of death to General Motors Acceptance Corp. under a purchase contract for a 196 [5] Cadillac.
“2. The sum of $9,777.44 for counsel fees actually expended and required for legal services rendered in the administration of this estate, including Federal Estate Tax Return and disputed audit, and Inheritance Tax Returns for Massachusetts and Virginia”.

Section 1001(2) of the Pennsylvania Inheritance and Estate Tax Act of June 15, 1961, P. L. 373, 72 PS §2485-1001(2), authorizes the personal representa[171]*171tive, after due notice, to have the correctness of the disallowance of deductions determined at the audit of his account.

Counsel for the Commonwealth offered its inheritance tax appraisement in evidence and rested.

A written stipulation of facts, entered into between counsel for accountant and the Commonwealth, relating to decedent’s debt to General Motors Acceptance Corporation (GMAC), was submitted. The facts are not in dispute. The stipulation recites that on March 13, 1965, decedent entered into a written “conditional sale contract” with Scott-Smith Cadillac Co. (Scott-Smith) to purchase a 1965 Cadillac for $6,286.35; Scott-Smith accepted decedent’s 1962 auto at a value of $2,821.35 as a down payment. The contract (stipulation, exhibit A) also authorized Scott-Smith to apply for coverage under a group life insurance policy from the Prudential Insurance Company of America (Prudential) on decedent’s life in an amount of the reducing balances owing on the purchase price, payable on death to GMAC, vendor’s assignee. The $43.62 premium cost under the Prudential policy was charged to decedent on his sales contract. Decedent agreed to pay Scott-Smith the $3,465 balance of the purchase price, together with $578.46 finance charges and $43.62 premium, a total of $4,087.08, in 36 equal monthly installments of $113.53 each. Scott-Smith immediately assigned the sales contract to GMAC. Decedent made three consecutive monthly payments of $113.53 each, in accordance with his contract, so that at the time of his death there remained a balance owing of $3,746.49. Prudential originally denied any liability to GMAC on the ground that the insured in his application for insurance misrepresented his health as good when he knew as a fact that this was untrue. Both Scott-Smith and GMAC demanded payment of the $3,746.49 from decedent’s personal representative [172]*172(exhibit D of stipulation). However, after further investigation, Prudential paid GMAC the sum of $3,-746.49 in full discharge of decedent’s debt. The stipulation further recites that decedent’s 1965 Cadillac sedan was inventoried in decedent’s estate and included as an asset in the inheritance tax report filed by decedent’s personal representative at its fair market value of $4,850. The sum of $3,746.49 claimed by GMAC was included as a debt, but disallowed by the Commonwealth as a deduction.

The copy of the Prudential group creditor’s insurance policy no. GL-360 issued to GMAC insuring the lives of “certain debtors”, as well as the sample certificate issued on the life of each debtor, were submitted and are hereto attached. The certificate recites, inter alia: “This Certificate is issued on the basis of debtor’s statement of good health, to induce Prudential to effect the insurance, made in a written instrument signed by him in connection with the obligation”. The “written instrument”, so called, is the conditional sale contract, copy of which is attached to the stipulation as exhibit “A”.

The reverse side of exhibit “A”, under the heading “Provisions”, reserves “title” in Scott-Smith and its assignee, so that GMAC retained a lien for the balance of the purchase price against the Cadillac which decedent purchased. Express statutory authority for the seller to hold the indicia of title, even though the conditional buyer is recognized as the “owner”, is granted by The Vehicle Code. See definition of “owner”, section 102 of the Act of April 29, 1959, P. L. 58, as amended, 75 PS §102, and section 201, “Certificate of Title”, 75 PS §§201 et seq. It should be noted that under paragraph 11 (c) (1), the right to apply the insurance to payment of the buyer’s obligation is expressly reserved to the seller.

The issue, as stated by the Commonwealth, is [173]*173whether the disallowed item constitutes a “debt” of decedent under sections 631 to 640 of the Act of 1961. Counsel for the Commonwealth contend that in order to qualify as a debt, payment of the obligation must come from an “asset of the decedent”, even though it is not part of his taxable estate. While conceding that this group life insurance is expressly exempt from tax under section 303, there is a significant failure by counsel for the Commonwealth to explain why it is not, nevertheless, an asset of decedent’s gross estate.

I am informed that this is a case of first impression.

Article VI of the Inheritance and Estate Tax Act of 1961 is headed “Deductions” with six subchapters. Three of these subdivisions, denominated “A. In General”, “B. Expenses — Deductible”, and “D. Liabilities —Deductible”, are pertinent to our problem. We shall first take note of: “Section 631. Liabilities of the Decedent; In General. — All liabilities of the decedent shall be deductible, subject to the limitations hereinafter set forth”; and then “Section 632. Debts Based Upon Contract or Agreement; In General. — Except as otherwise provided in sections 638 and 639 [here not relevant since 638 involves pledge to an exempt transferee and 639 involves liability for a tort or as an accommodation party], the deductions hereinafter set forth for indebtedness of the decedent, when founded upon a promise or agreement, shall be limited to the extent that it was contracted bona fide and for an adequate and full consideration in money or money’s worth”.

It cannot be successfully contended that Scott-Smith and GMAC’s claim against decedent’s estate for the unpaid balance of $3,746.49, at the time of decedent’s death and at the time when Prudential denied its liability on the group policy, was not such a liability of decedent’s estate as to qualify as a deduction under section 631, or that it was not “contracted bona fide [174]

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Bluebook (online)
42 Pa. D. & C.2d 169, 1967 Pa. Dist. & Cnty. Dec. LEXIS 121, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-estate-paorphctphilad-1967.