Zarlenga v. Zarlenga

2020 Ohio 6947
CourtOhio Court of Appeals
DecidedDecember 24, 2020
Docket2019 MA 89
StatusPublished

This text of 2020 Ohio 6947 (Zarlenga v. Zarlenga) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Zarlenga v. Zarlenga, 2020 Ohio 6947 (Ohio Ct. App. 2020).

Opinion

[Cite as Zarlenga v. Zarlenga, 2020-Ohio-6947.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF MAHONING )

CARMINE R. ZARLENGA III, TRUSTEE, C.A. No. 2019 MA 89 et al.

Appellees APPEAL FROM JUDGMENT v. ENTERED IN THE COURT OF COMMON PLEAS DANIEL J. ZARLENGA, TRUSTEE COUNTY OF MAHONING, OHIO CASE No. 2018 CI 0003 Appellant

DECISION AND JOURNAL ENTRY

Dated: December 24, 2020

TEODOSIO, Judge.

{¶1} Defendant-Appellant, Daniel Zarlenga (“Daniel”), appeals from the judgment of

the Mahoning County Court of Common Pleas, Probate Division, removing him as co-trustee and

trust advisor of his father’s trusts and ordering him to pay the trusts more than $2.8 million. This

Court affirms.

I.

{¶2} Daniel is the son of Carmine R. Zarlenga, Jr. (“Father”). Father and Daniel’s

grandfather established three companies during their lifetimes: The Acme Company (“Acme”), C-

Z Trucking Company, Inc. (“C-Z Trucking”), and C-Z Construction and Development Company

(“C-Z Construction”). Father eventually took control of all three companies as both president and

majority shareholder. He also married and had seven children. As he grew older and his health

declined, he sought to ensure that his companies would remain family owned and operated 2

businesses. He also sought to ensure that his wife, Martha Zarlenga (“Mother”), would be provided

for if he predeceased her.

{¶3} Father’s desire to protect the companies, minimize his potential estate tax liabilities,

and provide for Mother resulted in him constructing a comprehensive estate plan in 1995. He

called upon two of his sons, Daniel and Carmine R. Zarlenga, III (“Carmine”), to help carry out

his plan. Father established irrevocable trusts for Daniel and Carmine and executed a buy/sell

agreement between himself, Acme, C-Z Trucking, and his son’s trusts. Around the same time,

Daniel and Carmine executed the Zarlenga Family Partnership Agreement (“the Partnership”),

which was an agreement between their respective trusts. The buy/sell agreement and the

Partnership incorporated one another and placed restrictions on the sale and purchase of Father’s

shares in the family companies, as well as the eventual sale of any shares owned by Daniel or

Carmine. The documents also provided that the Partnership would serve as the beneficiary of

Father’s and Mother’s life insurance policies. Both documents indicated that the insurance was

“intended to be in an amount sufficient to provide the funds necessary to purchase [Father’s] shares

of stock in the [family companies].” After the foregoing documents were executed, Father

executed his will and a declaration of trust.

{¶4} Father bequeathed his tangible personal property and interest in his residential real

estate to Mother and bequeathed the remainder of his estate to his trust. Upon his death, his trust

provided for the creation of both a Marital Deduction Trust (“the Marital Trust”) and a Family

Trust (“the Family Trust”). A designated fraction of his estate would fund the Marital Trust, and

the remainder would fund the Family Trust. Mother would receive an income from both trusts on

an installment basis and their principals would remain intact unless needed “for her health, support

and maintenance.” A restrictive covenant in the Family Trust further provided that its principal 3

could not be distributed for Mother’s care until the funds in the Marital Trust had been exhausted.

Upon Mother’s death, the residue of Father’s trust would be divided equally among their seven

children.

{¶5} Father designated Daniel and Carmine co-trustees of his trust. He also designated

Daniel trust advisor “for the purpose of approving of all trust investments, sales and purchases”

and for “vot[ing] all shares of any closely-held corporation stock, other than that of [C-Z

Construction], held in the Trust.” When Father died in 2003, his controlling interest in each of the

family companies transferred to his trust. Daniel became president of each company and owned

approximately 20% of their shares, but the trust held the remaining 80%. Father’s trust also had

limited liquidity because a significant portion of its assets were Father’s shares in the companies.

Father’s original estate plan called for those shares to be held by the trust until Mother died. At

that point, the shares could be purchased by the surviving shareholder(s).

{¶6} In 2005, Daniel and Carmine decided to expedite the sale of stock in the companies

that was set to occur upon Mother’s death. They planned for each company to purchase its stock

from the Marital Trust and/or Family Trust. Their plan meant that Daniel would essentially be

able to control 100% of the stock (i.e., by owning 20% and running the companies that owned

80%) and the trusts would increase their liquidity to better provide for Mother during her lifetime.

To execute their plan, the companies and the trusts entered into a series of agreements:

 Acme signed a promissory note with the Family Trust, as well as a stock redemption

agreement and stock pledge agreement. Acme agreed to pay the Family Trust

$132,561, plus 6% interest, over 120 monthly installments to purchase its stock and

pledged stock certificates as security for its payment obligation. 4

 Acme signed a promissory note with the Marital Trust, as well as a stock

redemption agreement and stock pledge agreement. Acme agreed to pay the

Marital Trust $252,315, plus 6% interest, over 120 monthly installments to

purchase of its stock and pledged stock certificates as security for its payment

obligation.

 C-Z Trucking signed a promissory note with the Marital Trust, as well as a stock

redemption agreement. C-Z Trucking agreed to pay the Marital Trust $128,506,

plus 6% interest, over 120 monthly installments to purchase its stock.

 C-Z Construction signed a promissory note with the Family Trust, as well as a stock

redemption agreement. C-Z Construction agreed to pay the Family Trust $926,618,

plus 6% interest, over 120 monthly installments to purchase its stock.

As part of their respective agreements, each company tendered a down payment on the purchase

of its stock. The down payments were in addition to the amounts each company promised to pay

by way of promissory note.

{¶7} Although all three companies promised to make installment payments to the trusts

on their respective promissory notes, they did not follow through on their obligations. C-Z

Construction failed to make a single payment on its note, Acme stopped paying on its notes by

2008, and C-Z Trucking stopped paying on its note in 2009. Each of the promissory notes

contained default provisions, but neither Daniel, nor Carmine invoked those provisions when the

companies failed to pay. Daniel informed Carmine that the companies were struggling financially,

and neither brother wanted to see them to fail. It was Carmine’s understanding that the companies

would resume (or, in the case of C-Z Construction, begin) paying on the notes when they were 5

financially able to do so. Moreover, he believed the Partnership would eventually be able to use

Mother’s life insurance proceeds to help pay off the notes.

{¶8} While both Carmine and Daniel enjoyed the title of co-trustee, Daniel possessed

certain information that Carmine lacked. Carmine was a partner in a large law firm, lived out-of-

state, and only visited about twice a year.

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