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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
ORPHANS' COURT DIVISION
IN RE:
ESTATE OF SENECA C. ALLEN, Deceased
o
No. 2006-0152
FAMILY SETTLEMENT AGREEMENT
AGREEMENT executed thiSd-~ay of March, 2007, by and between
DARAN J. ALLEN, Individually and as, Execubix of the Estate of SENECA
C. ALLEN, Deceased, and KIMBERLY A. ALLEN, Individually and as,
Executrix of the Estate of SENECA C. ALLEN, Deceased,
WITNESSETH:
WHEREAS, Senec A. Allen died intestate on February 6, 2006;
WHEREAS, on February 16, 2006, the Register of Wills of Cumberland
County granted letters of administration to Oaran J. Allen and Kimberly A. Allen;
WHEREAS, the Administrators have proceeded with the administration of
said estate and have prepared an informal accounting of their administration;
WHEREAS, the Administrators have ... prepared and filed an original
Inheritance Tax Return as evidenced by the Return attached hereto as Exhibit
"A".
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NOW THEREFORE, the parties intending to be legally bound hereby,
mutually agree as follows:
1. The parties hereto, and each of them, agree and acknowledge that
they have fully and carefully examined the informal accounting prepared by
Daran J. and Kimberly A. Allen as co-administrators of the Estate of Seneca C.
Allen, Deceased, and find it to be true and correct and acceptable to the parties
hereto and each of them, and further that each of them has received a copy of
this Agreement and informal accounting.
2. The parties hereto do hereby release, remise and forever discharge
the Estate of and from all manner and acts, suits, claims, accounts, accountings,
debts, dues and demand whatsoever which they or any of them or their legal
representative or assigns may at any time hereafter have, against the
Administrators of said estate or the assets thereof, from, for, touching or
concerning any of the assets and property of the said estate and/or any claim or
interest thereto or therein and the administration, management, collection, sale or
distribution of any of said assets and for on account of any money, interest,
income assets or proceeds of the same, from the time of said decedent's death
to and including the date of this Agreement and the distribution authorized
herein.
3. This instrument is a full and final Family Settlement Agreement by
and between the parties hereto, both fiduciary and individual, all of the same
having been arrived at, included and executed after a full and cornplete
disclosure of the assets of said estate and the right of the parties therein and
thereto and all the parties hereto, and each of them agrees to abide by the terms
hereof.
4. The parties hereto, and each of them agree, that they will at all
tirnes in the future and whenever necessary appropriate or conveniently make,
execute and deliver to said Administrators and/or to the other party or persons,
any and all instruments, documents, conveyances, deeds, releases or other
instruments of any kind necessary or convenient to carry out the intention of this
agreement and/or to permit, assist and enable the Executrix to fulfill her duties
with references to the said estate and all the assets thereof.
5. This Agreement constitutes the entire understanding arnong the
parties hereto and each of them acknowledges that no representations or
statement of any kind, written or oral have been made to them by any of them
prior hereto except as provided for in this agreement, by the Administrators or by
any other person or party upon her behalf.
6. This Agreement shall inure to the benefit of and shall be binding
upon, the parties hereto, and each of them, their heirs, executors, administrators,
successors and assigns.
7. The signatories to this Family Settlement Agreernent agree to
refund to the estate prorata any amount which may be necessary in the Mure to
discharge c:lny liabilities of the estate which may hereafter arise.
8. This Family Settlement Agreement is signed and executed by the
Administrators and the other beneficiaries as withessed by the individual
signatures attached to the body of this Agreement.
9. This Agreement shall be governed by laws of the Commonwealth of
Pennsylvania.
IN WITNESS WHEREOF, the parties hereto have hereunto set their
r,espective hands and seals.
Date 1('" 'Ib 7
57 .~ If
Daran J. Allen, Individually and as Co-
Administrator of the Estate of Seneca C.
Allen
Date ] /"l")
EXHIBIT A
. ..'- ...-,. -. .. -~ .~. -~- - \
--I
15056051058
REV.1500 EX (06-05)
PA DepaJtment of Revenue '*
Btnau of IncIIvIduaI Taxes
PO BOX 280601
HanIsIug, PA 17128-0601
ENTER DECEDENT INFORMATlON BELOW
~a~Sec:urlty Number [)~te of.[).~~_ .
OFFICIAL USE ONLY
County Code Year
INHERITANCE TAX RETURN
RESIDENT DECEDENT 21
File Nunber
06
.0152
Date of Birth
".. ,... ~ .. --
: 206-78-8613
0210612006
0510512000
Decedenfs Last Name
Suffix
Decedenfs First Name
. Seneca
...
,C
.. .
. Allen
(If Applicable) Enter Surviving Spouse'. Infonnatlon Below
~~lJlIt):sLast Name Suffix
S~~~'~.F~':I~me._
MI
5.J:lC?lJae's S~I ~curity t.lum~!
THIS RETURN MUST BE RLED IN DUPUCATE WITH THE
REGISTER OF WILLS
FILL IN APPROPRIATE OVALS BELOW
~a> 1. Original Return C;I
2. Supplemental Return
C)
3. Remainder Retum (date of death
prior to 12-13-82)
5. Federal Estate Tax Retum Required
c=;. 4. Umltad Estate
C':) 48. Future Interest Compromise (dete of c::>
death after 12-12-82)
c::> 7. Decedent Maintained a LMng Trust
(Attach Copy of Trust)
c::;) 10. Spousal Poverty Credit (date of death C) 11. Election to tax under See. 9113(A)
betwe.l12-31-91 and 1-1-95) (Attach SOO. 0)
CORRESPONDENT - THIS SECllON MUST BE COMPL!TED. ALL CORRESPONDENCE AND CONFlDENlW. TAX INFORiIA.11ON SHOULD BE DIRECTED TO:
Name .... ...____._d~_._._..__.q_...u ._..._...._ _... .... gaytl!!"':r:~~~~~_~':!.~~!.__._.__.__
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8. Total Number of Safe Deposit Boxes
~ 6. Decedent DIed Testate
(Attach Copy of Will)
ce.> 9. LItIgation Proc:eeda ReceIwd
. James G. Nealon, III
(717) 232-9900
; F.!nTl . t.l8.I1l_e (If '.'P~C?a.I>I~) . . ..
. Nealon, Gover & Perry
First line of address
I REGISTER OF WILLS USE ONLY
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; 2411 North Front Street
-_....
~~or F.'~t9..mce
Harrisburg
State
PA
ZIP Code
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L____~
DATE FLED
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Second line of address
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17110
Correspondenfs e-maIl address:jnealon@ngplawfinn.com
Under penalties of peIjuIy, I decI8re \hat I h8ve examined this retum, including accompanying schedules and statements, and to the best of my knawIedge and belief,
It Is true, COmICl and axnpIeIe. DeclaratIon of P!Pf'8l' other then the P8l'801'l8ll'Sp1'a8ntatlve Is based on aU information of which prepIII8r hell any knowledge.
~OF"'-~-'~U1. I~ 3{~'767
SIGNATURE OF PREPARER OTHER THAN REPRESENTATIVE
DATE
ADDRESS
PLEASE USE ORIGINAL FORM ONLY
Side 1
L
15056051058
15056051058
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15056052059
REV.1500 EX
Decedent', Name:
RECAPITULATION
Seneca Allen
Decedent's SocIal Security Number
! 206-78-8613
1. Real estate (Schedule A). ............... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1.
2. Stocks and Bonds (Schedule B) .. . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2.
3. Closely Held Corporation, Partnership or Sole-Proprietorship (Schedule C) ..... 3.
4. Mortgages & Notes Receivable (Schedule D) . . .. .. . .. . . . . .. . . . .. . . . . . . . . . 4.
5. Cash, Bank Deposits & Miscellaneous Personal Property (Schedule E) . . . . . . . . 5.
6. Jointly Owned Property (Schedule F) c::> Separate Billing Requested . . . . . . . 6.
7. Inter-VIvos Transfers & Miscellaneous Non-Probate Property
(Schedule G) c::> Separate Billing Requested.. . . . . . . 7.
8. Total Gross Assets (total Lines 1-7). . . .. . . . . . . .. .. .. . . . .. . . .. . . . . . . . . .. 8.
9. Funeral Expenses & Administrative Costs (Schedule H). . . . . . . . . . . . . . . . . . . . . 9.
10. Debts of Decedent, Mortgage Liabilities, & Uens (Schedule I). .. . . . . . . .. .. . . . 10.
11. Total Deductions (total Lines 9 & 10). . .. . . . . .. ... . .. . . .. .. .. . ,. . ... . . .. 11.
12. Net Value of Estate (Line 8 minus Line 11) . . .. . .. .. . . . . . . . . .. .. . . .. . .. .. 12.
13. Charitable and Governmental BequestsJSec 9113 Trusts for which
an election to tax has not been made (Schedule J) .. . . . . . . . . . . . . . . . . . . . . . . 13.
14. Net Value Subject to Tax (Une 12 minus Une 13) .. . . ... .. .. .. . . . . .. . . . . . 14.
TAX COMPUTATION - SEE INSTRUCTIONS FOR APPLICABLE RATES
15. Amount of Line 14 taxable
at the-spousal tax rate, or
transfers under Sec. 9116 !
(a)(1.2) X .0_ 15.
16. Amount of Une 14 taxable
at lineal rate X.O _ 16.
17. Amount of Une 14 taxable
at sibling rate X .12 17.
18. Amount of Line 14 taxable
at collateral rate X .15 i 18.
19. TAX DUE. . . . . . . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19.
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20. FILL IN THE OVAL IF YOU ARE REQUESTING A REFUND OF AN OVERPAYMENT ~
N'd --ril-x rkll..- -- ~ 0.. f/-o..c
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15056052059
Side 2
15056052059
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REV-1500 EX Page 3
Decedent's Complete Address:
F1....Number. . .
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, 21 :1 06 '0152
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S NAME DECEDENT'S SOCIAL SECURITY NUMBER
Seneca C Allen 206-78-8613
STREET ADDRESS
CITY I STATE I ZIP
Tax Payments and Credits:
1. Tax Due (Page 2 Une 19)
2. CrediIsIPayments
A. Spousal Poverty Credit
B.PriorPayments
C. Discount
(1)
0.00
Total Credits ( A + B + C ) (2)
3. InterestlPenalty if applicable
D. Interest
E. Penalty
TotallnterestlPenalty ( D + E ) (3)
4. If Une 2 is greater than Una 1 + Una 3, enter the difference. This is the OVERPAYMENT.
Fill In oval on Page 2, Una 20 to request a refund. (4)
B. Enter the total of Una 5 + SA. This is the BALANCE DUE.
(5)
(SA)
(5B)
0.00
5. If Una 1 + Una 3 is greater than Une 2, enter the difference. This is the TAX DUE.
A. Enter the interest on the tax due.
0.00
Make Check Payable to: REGISTER OF WILLS, AGENT
PLEASE ANSWER THE FOllOWING QUESTIONS BY PLACING AN "X. IN THE APPROPRIATE BLOCKS
1. Did decedent make a transfer and: Yes No
a. retain the use or income of the property transferred;.......................................................................................... 0 [il
b. retain the right to designate who shall use the property transferred or its income; ............................................ 0 [il
c. retain a reversionary interest; or.......................................................................................................................... 0 iii
d. receive the promise for life of either payments, benefits or care? ...................................................................... 0 iii
2. If death occurred after December 12, 1982, did decedent transfer property within one year of death
without receiving adequate consideration? .............................................................................................................. 0 iii
3. Did decedent own an "in trust for" or payable upon death bank account or security at his or her death? .............. 0 iii
4. Did decedent own an Individual Retirement Accoun~ annuity, or other non-probate property which
contains a beneficiary designation? ........................................................................................................................ 0 iii
IF THE ANSWER TO ANY OF THE ABOVE QUESTIONS IS YES, YOU MUST COMPLETE SCHEDULE G AND FILE IT AS PART OF THE RETURN.
For dates of death on or after July 1, 1994 and before January 1, 1995, the tax rate imposed on the net value of transfers to or for the use of the surviving spouse
is three (3) percent [72 P.S. !9116 (a) (1.1) (i)).
For dates of death on or after January 1, 1995, the tax rate imposed on the net value of transfers to or for the use of the surviving spouse is zero (0) percent
[72 P.S. !9116 (a) (1.1) Qi)). The statute does not exempt a transfer to a surviving spouse from tax, and the statutory requirements for disclosure of assets and
filing a tax return are stin applicable even if the surviving spoUse is the only beneficiary.
For dates of death on or after July 1, 2000:
The tax rate imposed on the net value of transfers from a deceased child twenty-one years of age or younger at death to or for the use of a natural paren~ an
adoptive parent or a stepparent of the child is zero (0) percent [72 P.S. ~9116(a)(1.2)].
The tax rate imposed on the net value of transfers to or for the use of the decedenfs lineal beneficiaries is four and one-half (4.5) percent, except as noted in
72 P.S. !9116(1.2) [72 P.S. ~9116(a)(1)].
The tax rate imposed on the net value of transfers to or for the use of the decedenfs siblings is twelve (12) percent [72 P.S. !9116(a)(1.3)]. A sibling is defined, under
Section 9102, as an indMdual who has at least one parent in common with the deceden~ whether by blood or adoption.
REV-1508 EX+ (6-98)
.
COMMONWEALTH OF PENNSYLVANIA
INHERITANCE TAX RETURN
RESIDENT DECEDENT
SCHEDULE E
CASH, BANK DEPOSITS, & MISC.
PERSONAL PROPERTY
ESTATE OF
Seneca C. Allen
FILE NUMBER
21-06-0152
Include the proceeds of Iftlgation and the date the proceeds were received by the estate.
All property jolntly-owned with right of survivorship must be disclosed on Schedule F.
ITEM VAlUE AT DATE
NUMBER DESCRIPTION OF DEATH
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L l' ~p~~ of litigation against Janet A.~~&S Transportation a~ N~~n~~ I~
L- .--1 ~r:nder seal to protect priv~Of parties. see attache~~~~:: amo~~t ~o~ S~bject to tax. see --I ;'
I ! (attached letter of Holly McClintock of Department of Revenue) I
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TOTAL (Also enter on line 5, Recapitulation) $ L___,~~~<~
(If more space Is needed, insert additional sheets of the same size)
WEB ADDRESS www.state.Da.US
BUREAU OF INDMDUAI. TAXES
INHERITANCE TAX DIVISION
PO Box 280601
tiARRIsBURG, PA 17128-0601
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF REVENUE
June 29, 2006
James G. Nealon, III, Esq.
Nealon Gover & Perry
2411 N. FrontSt.
Harrisburg, PA 17110
Re: Estate of Seneca Allen
File Number: 2106-0152
Date of Death: 2/6/06
Court Number: CCP Cumberland Co. No. 06-3038
Dear Mr. Nealon:
The Department of Revenue received a petition concerning the approval of Settlement
Claim to be filed on behalf of the above-referenced Estate in regard to. a wrongful death and
survival action. It was forwarded to this Bureau for the Commonwealth's approval of the
allocation of the proceeds paid to settle the actions.
Pursuant to the petition, the 5-year-old-decedent died as a result of a pedestrian/motor
vehicle acciderit. The heirs to the decedent's estate are her parents. Therefore, any proceeds
paid to settle the survival action would pass to the decedent's parents and would be subject to
a zero percent inheritance tax rate. 72 P.S. ~9116(a)(1.2). Accordingly, regardless of the
allocation of the subject proceeds, there would be no inheritance tax consequences.
Please be advised that based upon these facts and for inheritance tax purposes only,
this Department bas no objection to the proposed allocation of the proceeds of this action,
80% to the wrongful death claim and 20% to the survival claim. Proceeds 'of a survival action
are an asset included in the decedent's estate and, although subject to the imposition of a zero
percent inheritance tax rate in this instance, they must be reported on decedent's Pennsylvania
inheritance tax return. 42 Pa. C.S.A. ~8302; 72 P .S. ~~91 06, 9107. Costs and fees must be
deducted in the same percentages as the proceeds are allocated. In re Estate of Merrvman,
669 A,2d 1059 (Pa. Cmwlth. 1995).
I trust that this letter i~ a sufficient representation of the Department's position on this
matter. .As the Department has no objections to the Petition, an attorney from the-Department
of Revenue will not be attending the hearing regarding it. Please contact me if you or the Court
has any questions or requires anything additional from this Bureau. Finally, the approval of this
.allocation is limited to this estate and does not reflect the position that the Department-may
take in any other proposed distribution of proceeds of a wrongful death/survival action.
~ce"jIY, ...
~1.M~cL
Holly A, McClintock
Trust Valuation Specialist
PHONE: 717-787-1794 · FAX: 717-783-3467 · EMAlL: hmcclintoc@state.Da.us
..
~.
DARAN J. ALLEN and KIMBERLY A.
ALLEN, Individually and as
Co-Administrators of the ESTATE OF
SENECA C. ALLEN, Deceased,
Plaintiff .
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
~
NO..06-3038.
v.
: CIVIL AC.TION - LAW
JANET ADAMS and
B & 5 TRANSPORTATION, INC.,
Defendant
: JURY TRIAL DEMANDED
ORDER OF COURT
AND NOW, this . I 7 """ day of ~ ' 2006,
upon consideration of the 'Petition to Seal Settlement heretofore filed this Honorable Court
/'
directs the Prothonotary to place the settlement in this case under seal in order to
protect the privacy of the financial affairs of the Petitio.ners.
J.
'.
REV-1513 EX+ (9-00) .-
COMMOftlNEALTH OF pEtMY\.VANIA
INHERITANCE TAX RETURN
RESIDENT DECEDENT
SCHEDULE J
BENEFICIARIES
ESTATE OF
Seneca C. Allen
FILE NUMBER
21-Q6-0152
RELATIONSHIP TO DECEDENT AMOUNT OR SHARE
NUMBER NAME AND ADDRESS OF PERSON(S) RECEMNG PROPERTY Do Not Uat TI'Ultee(I) OF ESTATE
I TAXABLE DISTRIBUTIONS [Inc:Iude ou1rIghl spousal distributions, and transfers under
See. 9116 (a) (1.2)]
ENTER DOUARAMOUNTS FOR DISTRIBUTIONS SHOWN ABOVE ON LINES 15 THROUGH 18, AS APPROPRIATE, ON REV-1500 COVER SHEET
D NON-TAXABLE DISTRIBUTIONS:
A. SPOUSAL DISTRIBUTIONS UNDER SECTION 9113 FOR WHICH AN ELECTION TO TAX IS NOT BEING MADE
Daran J. Allen, father 1/2
Kimberly A. Allen 112
B. CHARITABLE AND GOVERNMENTAL DISTRIBUTIONS
TOTAL OF PART 11- ENTER TOTAL NON-TAXABLE DISTRIBUTIONS ON LINE 13 OF REV-1500 COVER SHEET $
(If more space is needed, Insert additional sheeIs of the same size)