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HomeMy WebLinkAbout10-25-07 b - 65SdS~P19 '\J , ,l-\,~ ~\dt. sB IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO. 21-06-455 FIRST AND FINAL ACCOUNT OF DIERDRE JAMES, EXECUTOR FOR ESTATE OF HENRY J. GROTHE ~,~l () -,.-,1 LATE OF MECHANICSBURG BOROUGH Date of Death: March 8, 2006 r ) Date of Executor's Appointment: June 9,2006 (-:) c,'. Advertising Grant of Letters: The Sentinel: November 4, 11 & 18 2006 Cumberland Law Journal: November 3, 10 & 17 2006 Accounting for the Period: March 8,2006 to September 30,2007 Purpose of Account: Dierdre James, Executor offers this account to acquaint interested parties with the transactions that have occurred during her administration of the estate. This account also indicates the proposed distribution of the estate. It is important that the account be carefully examined. Requests for additional information or questions or objections can be discussed with: Michael A. Scherer, Esquire O'Brien, Baric & Scherer 19 West South Street Carlisle, PA, 17013 (717) 249-6873 1 SUMMARY OF ACCOUNT Current Value Proposed Distribution of Specific Devise of Real Estate $112,932.61 $ 29,531.97 Proposed Distribution Residual Heir ------------ ------------ Principal Asset Value (Date of Death) Real Estate (Date of Death) TOTAL Less Disbursements Debts of Decedent Funeral Expenses Administration Expenses Federal and State Taxes Fees and Commissions IRS Penalty and Interest (Disputed) $ 25,402.61 $ 1,821.20 $ 3,904.85 $ 95,684.00 $ 35,070.00 $ 50.911.75 $ 212,794.41 TOTAL Balance before Distributions Distributions to Beneficiaries Principal Balance on Hand Real estate Balance on Hand 2 Fiduciary Acquisition Value $112,932.61 $204,035.32 $242,326.38 $112.932.61 $355,258.99 $29,531.97 None $29,531.97 $112,932.61 $ 29,531.97 RECEIPTS OF PRINCIPAL DESCRIPTION 1. Loan proceeds from Hank Grothe" 2. USAA Account ending # 6451 3. USAA Account Money Mkt # 42902815061 4. USAA Account S & P # 34900338083 5. USAA Account ending # 9240 6. Navy Federal Credit Union checking 7. Navy Federal Credit Union savings 8. 1994 Toyota 9. Veterans Administration Death Benefit 10. Claremont Nursing Home Refund 11. Cumberland County Nursing Home Refund 12. USAA Refund 13. Vanguard Investment Account TOTAL RECEIPTS OF PRINCIPAL VALUE $ 74,817.71 $ 12,685.08 $ 525.89 $ 52,468.06 $ 37,296.73 $ 738.26 $ 17,414.52 $ 1,000.00 $ 100.00 $ 20.39 $ 6,045.00 $ 923.68 $ 38.291.06 $ 242,326.38 RECEIPTS OF REAL ESTATE The decedent owned three parcels of real estate at the time of his death. Two parcels were owned as tenants in common with his son, Henry J. Grothe, II. They are: 1. 121 Cambridge Drive Mechanicsburg, PA 17055 Assessed Value Mortgage Payoff $ 143,840.00 $ 97,000.00 The decedent's interest was fifty percent. 2. 5505 Moreland Court Mechanicsburg, PA 17055 Assessed Value Mortgage Payoff $220,680.00 $128,925.42 The decedent's interest was fifty percent. individually: The decedent owned the following real estate, which was his former home, 3. 1096 Cocklin Street Mechanicsburg, PA 17055 Assessed value Mortgage Payoff $ 139,740.00 $ 96,104.68 The decedent's interest was one hundred percent. 3 DEBTS OF DECEDENT 1. 2. Claremont Nursing Home Insurance- USAA $ 25,309.62 $ 92.99 TOTAL DEBTS OF DECEDENT $ 25,402.61 FUNERAL EXPENSES 1. 2. Susan Grothe- obituary Geigle Funeral Home $ 193.20 $1.628.00 $1,821.20 TOTAL FUNERAL EXPENSES ADMINISTRATION EXPENSES 1. 2. 3. 4. Register of Wills Cumberland Law Journal The Sentinel Henry J. Grothe 11- tree removal $ 530.00 $ 75.00 $ 187.85 $3,112.00 $3,904.85 TOTAL ADMIN. EXPENSES FEDERAL AND STATE TAXES 1. 1998 Federal Income Tax 2. 1998 NY Income Tax 3. 2000 PA Income Tax 4. 2000 Federal Income Tax 5. 2000 NY Income Tax 6. 2001 PA Income Tax 7. 2001 Federal Income Tax 8. 2002 PA Income Tax 9. 2002 Federal Income Tax 10. 2004 Federal Income Tax 11. 2004 PA Income Tax 12. 2005 PA Income Tax 13. 2003 Federal Income Tax 14. 2003 PA Income Tax 15. 1999 Federal Income Tax 16. 1999 NY Income Tax $ 9,547.00 $ 2,619.00 $ 283.00 $ 7,678.00 $ 2,139.00 $ 679.00 $ 7,587.00 $ 376.00 $ 5,551.00 $ 2,831.00 $ 311 .00 $ 896.00 $ 8,664.00 $ 265.00 $ 28,279.00 $ 6,875.00 4 17. PA 2002 Interest and Penalty 18. Pennsylvania Inheritance Tax $ 304.88 $ 10.800.00 TOTAL FEDERAL AND STATE TAXES $ 95,684.00 FEES AND COMMISSIONS 1. 2. 2. Susan Stott, CPA O'Brien, Baric & Scherer-Attorney Fees Executor Fee $ 3,070.00 $ 12,000.00 $ 20.000.00 TOTAL FEES AND COMMISSIONS $ 35,070.00 PENALTIES AND INTEREST FOR LATE FILING OF STATE AND FEDERAL INCOME TAX RETURNS WHICH HAVE BEEN CLAIMED BY IRS BUT WHICH ARE BEING APPEALED 1. 2. 3. 4. 5. 6. 7. 8. 1998 Federal Interest and Penalty 1999 Federal Interest and Penalty 2000 Federal Penalty 2001 Federal Interest 2002 Federal Interest and Penalty 2003 Federal Interest and Penalty 2004 Federal Interest and Penalty 2007 Federal Penalty $ 8,360.24 $ 33,305.83 $ 972.17 $ 527.39 $ 3,141.04 $ 1,047.92 $ 3,529.01 $ 28.15 TOTAL INTEREST AND PENALTIES $ 50,911.75 TOTAL EXPENSES $212,794.41 DISTRIBUTIONS OF PRINCIPAL TO BENEFICIARIES 1. None. 5 PROPOSED DISTRIBUTION TO BENEFICIARIES The decedent's will at Item II devised his real estate to his son, Henry J. Grothe, II. The decedent had an interest in three parcels of real estate at his death. The first was his residence, located at 1096 Cocklin Street, Mechanicsburg, Pennsylvania, which was the decedent's residence. The decedent was the only titled owner of that real estate. The decedent also owned fifty percent of two investment properties, one of which was located at 121 Cambridge Drive, Mechanicsburg, Pennsylvania and other of which was located at 5505 Moreland Court, Mechanicsburg, Pennsylvania. The investment properties were owned by the decedent as tenants in common with his son, Henry J. Grothe, II. Henry J. Grothe II has managed all of the real estate since the decedent's death. The executor proposes to execute a deed conveying the Cocklin Street property to Henry J. Grothe, II and to execute deeds conveying the decedent's one half interest in the two investment properties to Henry J. Grothe, II. These conveyances would be contingent upon Henry J. Grothe, II obtaining financing to pay off the existing loans in which the decedent and Henry J. Grothe II are jointly liable or to assume the mortgages such that the decedent is no longer liable for the mortgage indebtedness. Under Item III of the decedent's will, the residue of his estate was bequeathed to the decedent's daughter, "Marsha A. Grothe, her heirs and assigns." Item VII of the decedent's will provided that "I purposely make no provision in this my Last Will for my son, Theodore Grothe, my daughter, Susan Grothe, my son, Paul Grothe, and my daughter, Gina Hunking, for reasons I deem just and proper." These provisions were the subject of petition for the interpretation of the decedent's will which litigation was resolved by the Honorable M.L. Ebert, Jr., wherein he Ordered that the residue of the estate be paid to Beverly Sokel. As can be seen above, the decedent failed to file federal income and state income tax returns dating to 1998. This resulted in the Executor spending considerable time and effort to gather income, expense and tax related data from multiple sources. Additionally, the late filing have resulted in the Internal Revenue Service and the PA Department of Revenue issuing notices for penalties and interest being due on the previously outstanding tax obligations. An appeal is being made to the Internal Revenue Service and the Department of Revenue to abate some of the interest and penalty charges. Approximately $50,000.00 has been assessed as penalty and interest. This tax situation has also delayed the filing of the Pennsylvania Inheritance Tax return, although a prepayment has been made towards that obligation. Additionally, the executor has spent a significant amount of time assisting undersigned counsel in the initiation and pursuit of the filing and disposition of the petition for the interpretation of the decedent's Will. The executor proposes to convey title to the real estate to the decedent's son at this time and to pay the residual heir the remainder of the estate at such time as the interest and penalty matters are resolved with the IRS and the PA Inheritance Tax is calculated precisely. ~L, Iv Michael A. Scherer, Esquire 19 W. South Street Carlisle, PA 17013 (717) 249-6873 Attorney for the Accountant 7 AUDIT NOTICE Please be advised that the First and Final Account and Proposed Distribution of Dierdre James, Executor under the Will dated May 5, 1999 and executed by Henry J. Grothe, Deceased, has been filed with the Clerk of the Orphans' Court Division of the Court of Common Pleas of Cumberland County, Pennsylvania, and will be called for audit before the Honorable Judges of said Court on Tuesday November 27,2007 at 9:00 a.m. in Courtroom No.2, Cumberland County Courthouse, Carlisle, Pennsylvania. Your interest in the Estate consists of: See attached Will and Schedule of Distribution. The Court will be asked to approve the account as stated and to make awards in accordance with provisions of the Will of Henry J. Grothe, Deceased. Copies of the account and Will are enclosed. It is not necessary that you or your counsel appear at the audit. However, if you have any objection to any items in the account (or, if you disagree with the position the accountant has taken on any claim), it is necessary that you appear at the time and place stated above in person or by counsel; otherwise, the Court will assume you have no objection and may approve the account as stated. If you have any questions regarding the contents of this letter, the account of the Executor or the Will of Henry J. Grothe, Deceased, please contact the undersigned. Mi~h&ESqUire 19 W. South Street Carlisle, PA 17013 (717) 249-6873 Attorney for the Accountant 8 10/24/2007 15:12 7172495755 aBS PAGE 02 VERI FICA TION Dierdre James, Executor of the Will of Henry J. Grothe, deceased hereby declares under oath that she has fully and faithfully discharged the duties of her office; that the foregoing First and Final Account is true and correct and fully discloses all significant transactions occurring during the accounting period; that all known claims against the Estate have been paid in full except for penalties and interest claimed by the Internal Revenue Service; that, to her knowledge, there are no claims outstanding against the Estate; that all income taxes presently due from the Estate have been paid, and that a prepayment is being made at this time towards the Pennsylvania Inheritance Tax and that a Pennsylvania Inheritance Tax Return will be filed upon resolution of IRS penalty and interest claims; and that the grant of Letters Testamentary and first complete advertisement thereof occurred more than four months before the filing of the foregoing First and Final Account. This statement is made subject to penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. D~~ Dierdre Ja e , Executor Date: \Old~/c)r CERTIFICATION UNDER C.C.R.P 6.3-1 I hereby certify that on October 25, 2007, I mailed the notice of the time and place of the presentation of the above account and proposed distribution, along with a copy of the account, proposed statement of distribution and a copy of the will, by first class mail, postage prepaid, as follows: Stephen J. Hogg, Esquire 1 9 South Hanover Street, Suite 101 Carlisle, Pennsylvania 17013 Robert P. Grubb, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 North Front Street Harrisburg, Pennsylvania 17110 Attorney for Beverly Sokel and Randolph Sokel Attorney for Gina Hunking and Susan Grothe Theodore Grothe 2001 Chrissy Lane Enola, Pennsylvania 17025 Henry Grothe, II 121 Cambridge Drive Mechanicsburg, Pennsylvania 17055 Paul Grothe 4 East Louther Street Carlisle, Pennsylvania 17013 1Yl?th ~ Michael A. Scherer, Esquire .,. .~ ( ~ ~ LAST WILL OF HENRY J. GROTHE I, HENRY J. GROTHE of Mechanicsburg, County of Cumberland, Commonwealth ~f Pennsylvani~, declare this to be my Last Will ~d revoke any Will previously made by me. ITEM I I direct that all my funeral expenses and all the expenses of my last illness be paid from my residuary estate as soon as practicable after my death as part of the expense of the administration of my estate. ITEM II I give, devise and bequeath .my real estate, whatsoever the same may be and wheresoever the same may be situate to my son, HENRY J. GROTHE, II, his heirs and assigns . ITEM m I give and bequeath the rest and remainder of my estate whatsoever the same may be and wheresoever the same may be situate to my daughter, MARSHA A. GROTHE, her heirs and assigns. t ~ ~ ~ ") ITEM IV I direct that all estate, inheritance and succession taxes paid out of the residue of my . estate with. the same effect as if taxes were expenses of administration, and all legacies, devises and other gifts made by this, my Last Will, shall be clear and free thereof. ITEM V I hereby appoint DIERDRE M. JAMES, ESQUIRE of Glenrock, New Jersey, as the Executrix of this, my Last Will. If DIERDRE M. JAMES, ESQUIRE, fails to qualify or ceases to act as Executrix, I appoint my nephew, WAYNE GRO~, of South hampton, New York, Executor of this, my Last Will. ITEM VI I direct that my Executor shall not be required to give bond for the faithful performance of his or her duty in any jurisdiction. ITEM VB I purposely make no provisions in this my Last Will for my son, THEODORE GROTHE, my daughter, SUSAN GROTHE, my son, PAUL GROTHE, and my daughter, GINA BUNKING. for reasons that I deem just and proper. 2 IN WITNESS WHEREOF. I have hereunto set my hand this s~ day of May. 1999. J~ ~4' Henry J~ This instrument. consisting of three pages. was. on the date thereof. signed, published and declared by Henry J. Grothe, the testator therein named, as and for his Last Will in the presence of us, who, at his request, in his presence, and in the presence of each other, have subscribed our names as witnesses hereto. ~~.s~~ Charles M. Suhr _~ O-~ 3 ...... .--".~"""'-'.'~'-,......~--~ ..- .....~, . COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS. We, . Henry J. Grothe , Charles M. Suhr , and Po,+t-I~ A.~~the testator and the witnesses, respectively, whose names are signed to the foregoing instrument, 1?eing fIrst dul~ sworn, do hereby declare to the lpldersigned authority that the testator signed and executed the instrument as his Last Will and that he had signed willingly, and that he executed it as a free and voluntary act for the purposes therein expressed, and that each of the witnesses, in the presence and hearing of the testator, signed the will as witness, and that, to the best of the witnesses' knowledge, the testator was at the time eighteen (18) years of age or older, of sound mind and under 110 ~ mny r L Henry ~i? ~~.c~, Charles M. Suhr .f2~ fl.~ Subscribed, sworn to and acknowledged before me by Henry J. Grothe, the testator, and subscribed and sworn to before my by Charles M. Suhr witnesses, this 5"tiJ day of May, 1999. and e:tricio. A. Gelho.u.r ' ~!lw );.~ Notary Public ";) My Commission expires: Notarial Seal \ Irene M. Knapik, Notary Public Harrisburg. Dauphin County MV Commission Expires Oct. 13, 2001 ~ INRE: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006-0455 ESTATE OF HENRY J. GROTHE ORPHANS' COURT DIVISION RE: INTERPRETATION OF WILL In this case the executrix and other potential heirs have requested an interpretation of Decedent's will. The Decedent's will is dated May 5, 1999 and contains the following bequest listed at "Item III": "I give and bequeath the rest and remainder of my estate whatsoever .the same may be and wheresoever the same may be situate to my daughter, Marsha A. Grothe, her heirs and assigns". The Decedent, Henry J. Grothe, died on March 8, 2006 and was a single man at the time. Marsha Grothe, the daughter listed in Item III, predeceased him and died on August 3,2001. Marsha died testate but without issue. Her last will and testament executed on December 31, 1991, made the following bequests: p .=:;:;0 A. The sum of Five Thousand Dollars ($5,000.00) to my friend"~;:g , ;~:~ :-) DAVID FREEDMAN of Berkeley, California. . .3;D . ~. oJ .-, '" ~ -...J ~ -~ ::::'.J . ~-J .' ~~) , ;1 ,'- .,:-) .' -', . ;. en ". -. -. .' ,"-. "1 :-=--~ -:~ '_ 1~:~O B. The sum of One Thousand Dollars ($1,000.00) to my godsof)c=:; - - ::::J .:u-i ~... -...,. STEVEN KEEZER of Danville, California. 6 (.,..> --..J ---~ -:.; .~ C. The residue of my estate shall go as follows: 1. One-half to my mother BEVERLY VELMA SOKEL. In the event she should predecease me or fail to survive me for a period of sixty (60) days, then the bequest made under this subparagraph 1 shall go to my stepfather JOSEPH SOKEL. In the event he should likewise predecease me or fail to survive me for a period of sixty (60) days, then the bequest made under this subparagraph 1 shall be added to and disposed of as provided under subparagraph 2 below. 2. One-half to my brother RANDOLPH THOMAS SOKEL of Westhampton, New York. In the event he shall predecease me or fail to survive me for a period of sixty (60 days), then to his children MICHAEL SOKEL and WESL Y SOKEL and any other children born to or adopted by him, by right of representation. At the time Henry Grothe died he had the following issue, Henry J. Grothe, II, Marsha Grothe (deceased), Theodore Grothe, Susan Grothe, Paul Grothe and Gina Hunking. In his will he bequeathed all of his real estate to his son Henry J. Grothe, II, his heirs and assigns. The remainder of his estate was bequeathed to Marsha J. Grothe, her heirs and assigns. In "Item VII" of his will the Decedent Henry Grothe stated the following: "I purposely make no provisions in this my Last Will for my son, Theodore Grothe,. my daughter, Susan Grothe, my son, Paul Grothe, and my daughter, Gina Hunking, for reasons that I deem just and proper". Respondents Susan Grothe and Gina Hunking claim that the Decedent's residual gift to Marsha fails because Marsha predeceased the Decedent and since Marsha left no issue they claim that Pennsylvania's anti-lapse statute does not save the gift. As a result they claim that the gift to Marsha falls into intestacy and therefore, must be divided pursuant to Pennsylvania's Intestacy laws, with the remainder of Henry Grothe's estate passing in equal shares to living children. The Executrix maintains that this interpretation fails to give affect to the phrase "her heirs and assigns" which immediately follows Marsha's name in the Decedent's will. This Court also notes that the children's interpretation violates the well settled principle "that one who writes a will is presumed to intend to dispose of all of his estate and not to die intestate as to any portion of it; accordingly, a will must be construed to avoid an intestacy if it is possible to do so, In re Carmany's Estate, 1947, 357 Pa. 296, 299,.53 2 A.2d 731, 732, 174 A. L. R. 311, and all doubts are resolved against intestacy. Siple v. Greumelli, 1947, 357 Pa. 237, 241, 53 A.2d 607". In re Butler's Estate, 364 Pa. 279, 282, 72 A.2d 110, 112 (1950). In interpreting the term "her heirs and assigns" the Rules of Construction of Wills found at 20 Pa.C.S.A. 92514 will be applied. Section 25~4(4) is titled "Meaning of 'Heirs' and 'Next of Kin'" etc.; time of ascertaining class. It provides in pertinent part that: "A devise or bequest of real or personal estate... to the testator's or another designated person's 'heirs' or 'next of kin' or 'relatives' or 'family' .,. or to 'the persons thereunto entitled under the intestate laws' or to persons described by words of similar import shall mean those persons... who would take under the intestate laws if the testator or other designated person were to die intestate at the time when the class is to be ascertained..." This rule would dictate that the words used in Henry Grothe's will which immediately follow the gift of the residuary to Marsha are to be understood to mean that if Marsha predeceased Henry, "heirs" means Marsha's intestate heirs. Since Marsha was not married at her death, and she had no children, the intestacy law found at 20 Pa.C.S.A. 92103 would then require that her Mother Beverly Sokel should inherit Marsha's lapsed gift. The children, Susan Grothe and Gina Hunking, object to such an interpretation. They rely on a series of cases in which the Courts of Pennsylvania have generally held the meaning of the words "heirs and assigns" are words of limitation and not purchase or succession. When "heirs and assigns" are used in this fashion they indicate the nature of the estate which is given and not the persons to whom it is to be given. See Estate of SYkes, 477 Pa. 254, 383 A.2d 920 (1978); In re Butler's Estate, 364 Pa. 279, 72 A.2d 110, (1950); In re Estate of Witte, 102 Pa.Super. 535,157 A. 328 (1931). Reliance on this meaning, however, fails to recognize some of the more fundamental principles of law outlined in these cases. 3 One such fundamental principle is the "cardinal rule that a will is to' be construed according to the intent of the testator." Estate of Sykes, 477 Pa. 254, 383 A.2d 920 (1978). In re Buehler's Estate, 16 Pa. D&C 524 (1931), relied on by the children to determine the meaning of the term "heirs and assigns," is based on the holding in In re Estate of Witte, 102 Pa.Super. 535, 157 A. 328 (1931). This case clearly indicates that the interpretation of the words "heirs and assigns forever" as words of limitation and not succession "prevails unless it plainly appears from the context of the will that such was not the testator's intention" Id. at 538. There is nothing clearer in the will of Henry Grothe than his declaration in Item VII that he did not want Susan Grothe and Gina Hunking to inherit anything. The Sykes case is therefore not analogous. In that case, the intent of the testator to disinherit his adopted children in favor of individuals of blood descent was not clearly stated. In this case, the intent to disinherit is crystal clear. There is no question in Pennsylvania that a person can disinherit his children. "Respected men and women, as well as eccentric people, sometimes make sound and sometimes eccentric wills. Courts, heirs and excluded beneficiaries often wish (1) they could change or delete clear and plain and specific language or (2) rewrite a will to expand or change the testator's bounty in order to conform to what they believe would be a fairer or wiser or to conform to what they think the testator would have said if he had foreseen the existing facts and circumstances. But that is not and never has been the law of Pennsylvania". In re Estate of Little, 403 Pa. 534,536-37,170 A.2d 106, 107 (1961 ). The children assert that it would never have been the intent of the decedent to have his former wife be his contingent heir. However, the record before this Court does not establish this contention. One fact that does stand out is that the decedent obviously knew his daughter had died prior to him in 2001 and that he did not change his will in the 5 years following her death before he died. When all is said and done, the clear intent 4 stated in Henry Grothe's will is that Susan Grothe and Gina Hunking were to inherit nothing from him. Accordingly, in this case, to give affect to the entire phrase in question, "Marsha Grothe, her heirs and assigns", Pennsylvania law provides that Henry intended to give the residuary of his estate to Marsha's "heirs" as defined in the Rules of Construction. Those "heirs" would be people who w,?uld inherit if Marsha died intestate. The laws of intestacy would first have provided for Marsha's spouse and children to inherit her estate and in default of same to her parents. Since Henry was her father, her only remaining parent and Henry's ex:"wife, Beverly Sokel is to receive the gift according to law. By the Court, "\ \ 1(" \ 07 ,~ J. Date M. L. Ebert, Jr., Michael A. Scherer, Esquire 19 West South Street . Carlisle, PA 17013 Dierdre James, Esquire Conway, Farrell, Curtin & Kelly, P.C. 48 Wall Street, 20th Floor New York, NY 10005 Robert P. Grubb, Esquire Metzger, Wickersham, Knauss & Erb, P.C. 3211 North Front Street Harrisburg, PA 17110 Steven J. Hogg, Esquire 19 South Hanover Street Suite 101 Carlisle, PA 17013 bas 5 ; l t " PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYL VANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, V1Z: November 3, November 10, and November 17, 2006 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ~l~ is arie Coyne, E tor Grothe, Henry J.. dec'd. Late of Cumberland County. Executrix: Dtedre M. James, 48 Wall Street. 20th Floor. New York, NY 10005. Attorneys: Michael A. Scherer. EsqUire. O'BI1en, Banc & Scherer. 19 West South Street. Carlisle, Pennsylvan1a 17013, (717) 249- 6873. SWORN TO AND SUBSCRIBED before me this 17 day of November. 2006 NOTA IAl SEAL LOIS E. SNYDER, Notary Public Carlisle 8oro, Cumberland County My Commission Expires March 5, 2009 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tammy Shoemaker, Classified Advertising Manager, of The Sentinel, of the County and State aforesaid, being dilly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regu1arly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regu1ar editions and issues of THE SENTINEL on the following day(s) ~ovember04,11,18,2006 COpy OF NOTICE OF PUBLICATION Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of 3;:~ Sworn to and subscribed before me this 22nd. day of November 2006. C"-Aw.iJM, y? k~ ~otary blic My commission expires: '1/t!tJ f COMMONWEALTH OF PENNSYLVANIA NoCarlaI Seal CMsIina L. Wdfe. NoIary PubIc CartisIe Bore. Ct6rtleI1aIId CotIlty My Co ,Ill Iission ExpiIes Sepl1. 2008 Member. Pennsylvania Association Of Notaries COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION ESTATE OF HENRY J. GROTHE, DECEASED NO. 21-06-0455 PETITION FOR ADJUDICA TIONI STATEMENT OF PROPOSED DISTRIBUTION PURSUANT TO PA.O.C. RULE 6.9 Michael A. Scherer, Esquire 1.0. # 61974 O'Brien, Baric & Scherer 19 West South Street Carlisle, Pennsylvania 17013 Phone: (717) 249-6873 Fax: (717) 249-5755 Page 1 of 11 ( ) (-:> CT. Estate of Henry J. Grothe, Deceased 1. Name and address of Petitioner: Name: Dierdre M. James, Esquire Address: 48 Wall Street, 20th Floor, New York, New York 10005 Identify any executors or administrators who have not joined in the Petition for Adjudication and Statement of Proposed Distribution and state the reason: None. Is this the first accounting by this fiduciary? x yes no If not, identify prior accountings, the accounting periods covered, and the date of adjudication of the prior accounting. 2. Decedent died on March 8, 2006. x Letters Testamentary or Petitioner on June 9,2006. Letters of Administration were granted to Date of Will: May 5, 1999 Date of Codicil: None Date of Probate: June 9, 2006 Was a bond required? yes x no If yes, state amount: _ Are proofs of advertising of the grant of Letters attached? x yes no Dates of advertising of grant of letters: The Sentinel: November 4, 11 and 18, 2006 Cumberland Law Journal: November 3,10 and 17,2006 Page 2 of 11 Estate of Henry J. Grothe, Deceased 3. Was decedent survived by a spouse yes x no If yes, name the surviving spouse: 4. Has the surviving spouse filed or taken an elective share? yes x no If yes, date of election: 5. In the case of an intestacy, state the names of the decedent's surviving children or surviving issue of deceased children (if none, so state): 6. Did decedent marry after execution of Will or Codicil(s)? yes x no Were any children born to decedent after execution of Will or Codicil(s)? yes x no If yes, give names and dates of birth: Name: Date of Birth: 7. If required by the Medical Assistance Estate Recovery Act, 62 P.S. 9 1412, was a request for a statement of claim sent to the Department of Public Welfare? x yes no Page 3 of 11 Estate of Henry J. Grothe, Deceased 8. Written notice of the Audit as required by Pa. a.c. Rules 6.3, 6.7 and 6.8 has been or will be given to all parties in interest listed in item 9 below, all unpaid creditors and all claimants listed in item 10 below. In addition, notice of any questions requiring Adjudication as discussed in item 14 below has been or will be given to all persons affected thereby. A. If Notice has been given, attach a copy of the Notice as well as a list of the names and addresses of the parties receiving such Notice. B. If Notice is yet to be given, a copy of the Notice as well as a list of the names and addresses of the parties receiving such Notice shall be submitted at the Audit together with a statement executed by a Petitioner or counsel certifying that such notice has been given. C. If any personal entitled to Notice is not sui juris (e.g. minors or incapacitated persons), Notice of the Audit has been or will be given to the appropriate representative on such party's behalf as required by Pa. a.c. Rule 5.2. D. If any charitable interest is involved, Notice of the Audit has been or will also be given to the Attorney General as required under Pa. a.c. Rule 5.5. In addition, the Attorney General's clearance certificate (or proof of service of Notice and a copy of such Notice) must be submitted herewith or at that Audit. 9. List all parties (charitable and non-charitable) of whom Petitioner has notice or knowledge, having or claiming any interest in the estate as beneficiaries under the Will or Codicil or as intestate heirs if there is a complete or partial intestacy: A. State each party's relationship to the decedent and the nature of each party's interest(s): Name and Address of Each party Relationship Interest Stephen J. Hogg, Esquire 19 South Hanover Street, Suite 101 Carlisle, Pennsylvania 17013 former wife and former wife's son of the decedent Attorney for Beverly Sokel and Randolph Sokel Page 4 of 11 Robert P. Grubb, Esquire Metzger, Wickersham, Knauss & Erb 3211 North Front Street Harrisburg, Pennsylvania 17110 daughters of decedent Attorney for Susan Grothe and Gina Hunking Theodore Grothe 2001 Chrissy Lane Enola, Pennsylvania 17025 son of decedent Paul Grothe 4 East Louther Street Carlisle, Pennsylvania 17013 son of decedent Henry Grothe, II 121 Cambridge Drive Mechanicsburg, Pennsylvania 17055 son of decedent B. Identify each party who is not sui juris (e.g. minors or incapacitated persons). For each such party, give date of birth, the name of each Guardian and how each Guardian was appointed. If no Guardian was appointed, identify the next of kin of such party, giving the name, address and relationship of each. NONE. C. State why a Petition for GuardianITrustee Ad Litem has or has not been filed for this Audit. (see Pa. O.C. Rule 12.4). N/A D. If distribution is to be made to the personal representative of a deceased party, state date of death, date and place of grant of Letters and type of Letters granted. N/A Page 5 of 11 Estate of Henry J. Grothe, Deceased 10. Other than the claim for the family exemption, list the names of all known claimants and the amount of their claims and state whether each claim is admitted. Name and address Of Each Claimant Amount of Claim Claim Admitted Will Claim Be Paid In Full? Internal Revenue Service $50,911.75 Contested If Contest Fails If the estate is insolvent, attach a schedule setting forth the order of preference under 20 Pa.C.S. 9 3392 and the proposed payments. 11. Was family exemption claimed? yes x no Was family exemption allowed? yes no Family exemption claimant's name and relationship: Name: Relationship: Page 6 of 11 Estate of Henry J. Grothe, Deceased 12. The amount of Pennsylvania Transfer Inheritance Tax and additional Pennsylvania Estate Tax paid, the date(s) of payment(s), and the interest(s) upon which paid, are as follows: Date Payment Interest 10/25/07 $10,800.00 13. On the date of death, was the decedent a fiduciary (personal representative, trustee, guardian, agent under power of attorney) or surety on the bond of a fiduciary? yes x no If yes, provide the name of the estate, indicate whether an account has been filed and confirmed absolutely and all awards performed, or, in the alternative, how the decedent's estate will be discharged for the decedent's fiduciary administration of the estate. 14. A. Describe in detail any questions requiring adjudication and state the position of the Petitioner(s) as to each question: The only question remaining is whether the IRS will abate penalties and interest currently being assessed against the decedent. Susan Stott, CPA, has been retained by the estate and prepared and filed income tax returns that the decedent neglected to file dating to 1998. Ms. Stott advises that the penalties and interest which flow from the late filings may be abated partially if it is demonstrated to the IRS that the decedent had medical issues that explain the failure to file the returns. The executor is attempting to obtain the medical proof Ms. Stott has requested. Ms. Stott advises that the abatement process with the IRS is very uncertain as to timing and potential outcome. B. Has notice of the question requiring adjudication been given to the parties identified in Paragraph 9 above? X yes no Page 7 of 11 15. If Petitioner(s) has/have knowledge that a share has been assigned, renounced, disclaimed or attached, provide a copy of the assignment, renunciation, disclaimer or attachment, together with any relevant supporting documentation. Page 8 of 11 Estate of Henry J. Grothe, Deceased 16. Had the decedent been adjudicated an incapacitated person? _ yes --X- no If yes, attach a copy of the Order if available; otherwise state the Court, term, number, date and name of the Hearing Judge. 17. A. list or attach a separate list of additional receipts and disbursements since the closing of the Account. B. Has notice of the additional receipts and disbursement been given to the parties identified in Paragraph 9 above? yes no 18. If a reserve is requested, state amount and purpose. Amount: Entire residual estate. Purpose: After the tax matters with the IRS have been resolved the residual estate will be disbursed to Beverly Sokel. If a reserve is requested for counsel fees, has notice of the amount of fees to be paid from the reserve been given to the parties in interest? yes x no 19. Is the court being asked to direct the filing of a Schedule of Distribution? yes x no As to real estate only? yes no Page 9 of 11 Estate of Henry J. Grothe, Deceased Wherefore, your Petitioner asks that distribution be awarded to the parties entitled and suggests that the distributive shares of income and principal (residuary shares being stated in proportions, not amounts) are as follows: A. Real Estate: Proposed Distributee(s) Amount/Proportion Henry J. Grothe, II 121 Cambridge Drive, Mechancisburg, PA 17055 5505 Moreland Court Mechanicsburg, PA 170556 1096 Cocklin Street Mechanicsburg, PA 17055 B. Residuary Estate: Proposed Distributee(s) Amount/Proportion Beverly Sokel $29,531.97 plus IRS abatement Submitted By: Mi~it. Esquire Attorney for Petitioner, Dierdre James Page 10 of 11 10/24/2007 15:25 71 724'35755 DBS PAGE 22 Estate of Henry J. Grothe, Deceased VERIFICATION OF PETITIONER The undersigned hereby verifies that the facts set forth in the foregoing Petition For Adjudication/Statement of Proposed Distribution which are within the personal knowledge of the Petitioner are true, and as to facts based on the information of others, the Petitioner, after diligent Inquiry, believes them to be true; and that any false statements herein are made subject to the penalties of 18 Pa,C.S. ~ 4904 (relating to unsworn falsification to authorities). D~ James, Petitioner Dierdr CERTIFICATION OF COUNSEL The undersigned counsel hereby certifies that the foregoing Petition For Adjudication/Statement of Proposed Distribution is a true and accurate reproduction of the form Petition authorized by the Supreme Court, and that no changes to the form have been made beyond the responses herein. ~~tv Michael A. Scherer, Esquire Attorney for Petitioner Page 10 of 10 1 t ." PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYL VANIA SSe COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: November 3, November 10, and November 17, 2006 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ~~l~ is arie Coyne, E tor Grothe, Henry J., dec'd. Late of Cumberland County. Executrix: Dtedre M. James. 48 Wall Street. 20th Floor, New York. NY 10005. Attorneys: Michael A. Scherer. Esquire. O'BI1en. Bartc & Scherer, 19 West South Street. Carlisle. Pennsylvania 17013. (717) 249- 6873. SWORN TO AND SUBSCRIBED before me this 17 day of November. 2006 NOTA IAL SEAL LOIS E. SNYDER, Notary Public Carlisle Boro. Cumberland County My Commission Expires March 5, 2009 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tammy Shoemaker, Classified Advertising Manager, of The Sentinel, of the County and State aforesaid, being du1y sworn, deposes and says that THE SENTINEL, a newspaper of general circu1ation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of TIlE SENTINEL on the following day(s) ~ovember04,11,18,2006 COPY OF NOTICE OF PUBLICATION Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of ~~ Sworn to and subscribed before me this 22.nd. day of ~ovember 2006. C"-A.w.frAOI 'ct. k~ ~otary blic My commission expires: '1/t IIJ f COMMONWEALTH OF PENNSYLVANIA NolariaI Seal Christina L. Wdfe. NolaIy PubIc C8rfisIe Boro. Q.mertand Ccunty My Ca ,lI1lSSiOn ExpIres Sept 1. 2008 Member. Pennsylvania Association Of Nolaries