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HomeMy WebLinkAbout02-05-09 ,. ~. IN RE: ESTATE OF ROBERT A. BRADER, IN THE COURT OF COMMON PLEAS OF Late of the Borough of New Cumberland CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION • NO. 21-08-0895 PETITION TO APPROVE TERMINATION OF A TRUST To the Honorable Judges of the Orphans' Court Division: Petitioners, Mary A. Brader and Steven R. Brader, through their counsel, Johnson, Duffle, Stewart & Weidner, respectfully state the following in support of this Petition to Approve Termination of a Trust: Petitioners are Mary A. Brader and Steven R. Brader, adult individuals who reside at 2 Center Drive, Camp Hill, Pennsylvania 1701 1. 2. Robert A. Brader ("Decedent"), died on July 17, 2008, survived by his wife, Petitioner Mary A. Erader, and his son, Petitioner Steven R. Brader. 3. On September 3, 2008, the Register of Wills appointed Steven R. Brader Executor of Decedents Will dated December 1, 1997, a copy of which is attached as Exhibit ~ g r~ ~ ~ ~ i L c ' "..> „ S ~fj~ a c- --. '* i • ~ c' y 4. Article IV of Decedent's Will directs the distribution of the residue of the estate to a Trustee of a Trust which requires the payment of income (and so much of principal as is necessary for her support) to Petitioner, Mary A. Brader, for the rest of her life, and at her death, the Trust estate is to be distributed to Decedent's son, Steven R. Brader. 5. The Trust is a "credit by-pass" trust designed to minimize federal estate taxes. 6. Since the date of the execution of Decedent's Will in 1997, the federal estate tax law has been amended, and the tax savings purpose for which the credit by-pass Trust was originally created no longer exists. 7. The residue of the Decedent's Estate available to fund the Trust is approximately $450,000.00, subject to payment of the applicable debts, liabilities, expenses and costs of administration. 8. Petitioner Mary A. Brader is the Current Beneficiary, and Steven R. Brader is the Qualified Beneficiary of the Trust under §7723 of the Uniform Trust Code, 20 Pa. C.S.A. §7701 et seg. ("Code") 9. Pursuant to §7740.1(b) of the Code, the funding of the Trust is not necessary to reduce federal estate taxes, a material purpose of the Trust. 2 10. Pursuant to §7740.2 of the Code the change in the federal estate tax law constitutes a circumstance arising after the execution of Decedent's Will, not anticipated by the Decedent. 11. Manufacturers and Traders Trust Company, successor to Dauphin Deposit Bank and Trust Company, is the Trustee appointed in Decedent's will. 12. Manufacturers and Traders Trust Company has renounced its right to serve as Trustee and consents to the termination of the Trust, which Renunciation and Consent is attached as Exhibi± B. 13. Pursuant to § 7740.1(c), your Petitioners and beneficiaries of the Trust have agreed that upon approval of this Petition, the assets otherwise distributable to the Trustee shall be distributed directly to Mary A. Brader, Decedent's surviving spouse and the Current Beneficiary, free of Trust. 3 WHEREFORE, your Petitioners respectfully request this Honorable Court to enter a decree directing that the Trust under Article 1V of Decedent's Will be disregarded and the residuary assets of the Decedent's estate be distributed to Mary A. Brader, Decedent's surviving spouse and Current Beneficiary. Respectfully submitted JOHNSO/N~p, ~D~U~F~F~L~Ep,STEWART & WEIDNER Edmund G. Myers I.D. No. 20558 30] Market Street P.O. Box 109 Lemoyne, PA 17043 (717)761-4540 Attorney for Petitioner 353290x3 4 VERIFICATION The undersigned, verifies that the statements made in the foregoing Petition are true and correct and that false statements may subject the undersigned to the penalties of 18 Pa. C.S. §4804. Y' Date: ~ ~ 3 ~ Oy ~~ ~l,,J--- Steven R. Brader VERIFICATION The undersigned, verifies that the statements made in the foregoing Petition are true and correct and that false statements may subject the undersigned to the penalties of 18 Pa. C.S. §4804. Date: 2 ~ 3 (~ ~ `' % ~ ~',. ,~~~-~-rC-~// Mary A. Brader ~tt~t t11 ttn~ ~P~tttrnP~tt OF ROBERT A. BRADER I, ROBERT A. BRATiER, of the Borough of New Cumberland, Cumberland County, Pennsylvania, being of sound and disposing mind, memory and understanding, do hereby make, publish and declaze this as and for my Last Will and Testament, hereby revoking and making void any and all Wills or Codicils at any time heretofore made by me. ARTICLE I I direct the payment of all my legal debts, and the expenses of my last illness and funeral from my Estate as soon after my death as conveniently may be done. I authorize my Executrix or successor to expend funds from my Estate for the purchase, erection and inscription of a suitable grave marker. All the foregoing shall be considered expenses of the administration of my Estate. ARTICLE II I give and bequeath my automobile(s), household goods, personal effects and other tangible personality of like nature (not including cash or securifies), together with any existing insurance thereon, unto my wife, MARY A. BRADER, provided she survives me by thirty (30) days. In the event that my wife, MARY A. BRADER, is not living on the thirty-first (31st) day following my death, I give and bequeath such tangible personalty and insurance thereon unto my son, STEVEN R. BRADER. . 1_ ,..~ ARTICLE III ' . If my wife, MARY A. BRADER, survives me (and I direct that for the purposes of this Article of my Will she shall be deemed to have survived me unless it appears unmistakably that she predeceased me), and if the federal estate tax due because of my death will be reduced by making this gift for her benefit, I give, devise and bequeath unto my said wife, MARY A. BRADER, the least amount (based upon values as finally determined for federal estate tax purposes) as shall be needed for the federal estate tax unlimited marital deduction to reduce the federal estate tax to the lowest possible figure after full use of all other deductions and credits allowable in calculating the federal estate tax. However, the state death tax credit shall only be taken into account to the extent that it does not increase the amount of tax payable to any state. Accordingly, I direct that: A. If the marital deduction, or any other similaz benefit, is allowable with respect to any property, including property held by entireties, which my wife, MARY A. BRADER, has received prior to my death or at my death will receive otherwise than pursuant to this Article III, the value of such property shall be taken into consideration in calculating the size of the gift under this Article III. B. No property ineligible for the marital deduction, or any similar benefits, shall be distributed to this gift for my wife, MARY A. BRADER pursuant to this Article III. C. Either cash or investments or both maybe allocated to any gift under this Article III. D. Any property allocated under this Article III in kind shall be valued at the value which it is finally included in my gross estate for federal estate tax purposes, provided that the aggregate market value thereof on the date of allocafion (plus the value as fmally determined for federal estate tax purposes of all other property qualifying for the marital deduction) is at least equal to the dollar value of the marital deduction as finally determined for federal estate tax purposes. 2 ........... . E~ If any provision of my Will s1iaY1 resuit'in depriving my estate of the marital deduction for federal estate tax purposes, such provision is hereby revoked and my Will shall be read as if any portion thereof inconsistent with allowance of the marital deduction for federal estate tax purposes is null and void. ARTICLE IV If my wife, MARY A. BRADER, survives me, I give, devise and bequeath all the rest, residue, and remainder of my Estate, of whatsoever nature and wheresoever situate, unto my Trustee hereinafter named; IN TRUST, however to hold, manage, invest and reinvest the same for the following purposes: A. To pay the net income therefrom at least as often as quarter-annually unto my wife, MARY A. BRADER, for and during her lifetime. B. As much of the principal of this Trust as Trustee in its sole discretion may from time to time think advisable for my wife's health, maintenance, and support to maintain her in the station of life to which she is accustomed at my death, or during her illness or emergency, shall be either paid to her or else applied directly for her benefit by my Trustee after taking into account other assets and sources of income available to her. C. Trustee may apply the net income of this Trust for the support of my wife, MARY A. BRADER, should she by reason of age, illness or any other cause in the opinion of my Trustee be incapable of disbursing it. D. Upon the death of my wife, MARY A. BRADER, I direct my Trustee to distribute the balance of principal and undistributed income thereof unto my son, STEVEN R. BRADER If my son, STEVEN R. BRADER, is not living at the time of my wife's death, I direct the Trustee distribute the balance of principal and undistributed income as follows: 3 (1) one-half thereof unto my grandson, JOHN S. BRADER; and (2) one-half thereof unto Dauphin Deposit Bank and Trust Company in further Trust, to hold, invest, manage, and reinvest the same for the benefit of my daughter-in-law, BEVERLY A. BRADER, and to pay the net income therefrom unto my daughter-in-law, BEVERLY A. BRADER for and during the term of her natural life. Upon the death of my daughter-in-law, BEVERLY A. BRADER, or should she not be living at the time of my wife's death, I direct that the Trustee shall distribute the balance of principal and undistributed income unto my grandson, JOHN S. BRADER, if living, and if not living, then unto his then-living issue, per stirpes, by representafion. In the event that my grandson, JOHN S. BRADER, is not living at the time of my wife's death and is not survived by then-living issue, I direct that the Trustee distribute the balance of principal and the undistributed income unto ST. PAUL'S LUTHERAN CHURCH, 524 Bridge Street, New Cumberland, Pennsylvania. ARTICLE V If my wife, MARY A. BRADER, fails to survive me, I direct the following: A. I give and bequeath the sum of Ten Thousand ($10,000.00) Dollazs unto ST. PAUL'S LUTHERAN CHURCH, 524 Bridge Street, New Cumberland, Pennsylvania; B. I give and bequeath the sum of Fifty Thousand ($50,000.00) Dollars unto my grandson, JOHN S. BRADER; and C. I give, devise and bequeath all the rest, residue and remainder of my Estate, of whatsoever nature and wheresoever situate, unto my son, STEVEN R. BRADER. D. If my son, STEVEN R BRADER, fails to survive me, I give, devise and bequeath all the rest, residue and remainder of my Estate, of whatsoever nature and wheresoever situate as follows: 1. One-half thereof unto my grandson, JOHN S. BRADER; and 2. One-half thereof unto DAUPHIN DEPOSIT BANK AND TRUST COMPANY, 4 r in TRUST, to hold, invest, manage and reinvest the same for the benefit of my daughter- in-law, BEVERLY A. BRADER and to pay the net income therefrom unto my daughter- in-law, BEVERLY A. BRADER, for and during the term of her natural life. Upon the death of my daughter-in-law, BEVERLY A. BRADER or should she not survive me, I direct that the Trustee distribute the balance of principal and undistributed income unto my grandson, JOHN S. BRADER, if living, and if not living, then unto his then-living issue, per stirpes per representation. In the event that my grandson, JOHN S. BRADER, is not living at the time for distribution and is not survived by then-living issue, I direct that the Trustee distribute the balance of principal and net undistributed income unto ST. PAUL'S LUTHERAN CHURCH, 524 Bridge Street, New Cumberland, Pennsylvania. ARTICLE VI Should any person entitled to a shaze of my estate not have reached the age of twenty-five (25) years at the time for distribution to him or her, I devise and bequeath the share of each such person unto my TRUSTEE hereafter named, IN SEPARATE TRUST, to hold, manage, invest and reinvest the shaze so received, and to use and apply the income and principal, or so much thereof, as in Trustee's discretion, may be necessary to appropriate for such beneficiary's support and education (including college education, graduate and undergraduate and vocational training), without regard to his or her ability to provide for such support or education or to make payment for these purposes, without fi.n-they responsibility, to such beneficiary or to any person taking care of such beneficiary. At such time as the beneficiary attains the age of twenty-one (21) years, Trustee shall pay the net income therefrom unto him or her unfil said beneficiary attains the age of twenty-five (25) yeazs, at which time Trustee shall distribute the then-remaining principal and any income accumulated thereon unto such beneficiary absolutely, at which time the Trust as to that beneficiary shall terminate. In the event any beneficiary dies before receiving his or her final distribution hereunder, such beneficiary's Trust shall terminate and the balance of principal and income shall be distributed to his or her personal representative. 5 ARTICLE VII If at any rime during the continuance of any trust created hereunder, the Trustee, in its sole and absolute discretion, determines that the size of any individual Trust has become so small as to be impracfical to continue to hold in Trust and uneconomical to continue to administer as a Trust, then in such circumstances, the Trustee may, without further authorization, distribute the balance of the principal and income in such Trust to the beneficiary then-entitled to the income therefrom, and upon such distribution, the Trustee shall be released from further obligafion with respect to that Trust and shall not be subject to any claim from any person who may have had a future interest in such Trust had it been continued in Trust. ARTICLE VIII The interest of the beneficiaries hereunder or the beneficiaries of any Trust created herein shall not be subject to anticipation or to voluntary or involuntary alienafion. ARTICLE IX I direct that all death taxes shall be paid from my residuary estate passing under Article IV (or Article V, as the case may be) of this Will or, to the extent determined by my Personal Representative, by the Trustee from property (if any) distributable directly to the Trustee. In no event shall the payment thereof (i) reduce or otherwise affect the amount (if any) distributable under Article III except to the extent that property remaining in my gross estate after satisfaction or provision for satisfaction of all debts and expenses of administration, and all inter vivos and testamentary dispositions (other than under Article N or Article V) of property included in such gross estate which do not qualify for the federal estate tax marital deduction, shall be insufficient to satisfy all death taxes in full and (ii) be made from any property which is not includible in my estate for the purposes of one or more of such death taxes and which would be so i includible if used for such payment. 6 ARTICLE X My Personal Representafive and Trustee shall have the following powers in addition to those vested in them by law and by other provisions of my Will applicable to all property, whether principal or income, including property held for minors, exercisable without court approval and effective until actual distribution of all property: A. To have full authority to deal with any business interest as freely as I might in my lifetime. B. To make distribution in cash or in kind, or partly in cash and partly in kind, and in such manner as they may determine. C. To retain any or all of the assets of my estate, real or personal, without restriction to investments authorized for Pennsylvania fiduciaries, as they deem proper, without regard to any principle of diversification or risk. D. To invest in all forms of property without restriction to investments authorized for Pennsylvania fiduciaries, as they deem proper, without regazd to any principle of diversification or risk. E. To sell at public or private sale, to exchange, or to lease for any period of time any real or personal property and to give options for sales, exchanges or leases, for such prices and upon such terms or conditions as they deem proper. F. To allocate receipts and expenses to principal or income or partly to each as they from time to time think proper. G. To borrow from or to sell to my Tmstee even though such Trustee may be my personal 7 representative. H. To compromise any claim or controversy. ARTICLE XI I name, consttute and appoint DAUPHIN DEPOSIT BANK AND TRUST COMPANY, Trustee of any Trust created by me in this my Last Will. ARTICLE XII I name, constitute and appoint my wife, MARY A. BRADER, Executrix of this my Last Will and Testament. In the event my wife, MARY A. BRADER, fails to qualify of ceases to so act, I name, constitute and appoint my son, STEVEN R. BRADER, Alternate-Executor to complete the administration of my Estate. Should my son, STEVEN R. BRADER, also fail to qualify or cease to so act I name, constitute and appoint DAUPHIN DEPOSIT BANK AND TRUST COMPANY Alternate-Executor to complete the administration of my estate. I direct that no fiduciary appointed herein shall be required to i post bond for the faithful administration of the duties required in any jurisdiction. 8 IN VG'i/T///NESS WgH~EREO'F, I have hereunto set my hand and seal to this,gmy~Last ~'Wi11~an$~~~ Testament, thislJlyday of p-rc~„~,(lt,,. , 1997. %'~` Q' ~ /~u:~L~/iz~ (SEAL) ROBERT A. BRADER SIGNED, SEALED, PUBLISHED AND DECLARED by the above-named Testator, as and for his Last Will and Testament, in the presence of us, who at his request, in his presence and in the presence of each other, have hereunto subscribed our names as witnesses. 7 ~~~~ nl. cap ~. 9 ` ACIQVOV4'LEDGMENT COUNTY OF CUMBERLAND COMMONWEALTH OF PENNSYLVANIA SS We, ROBERT A. BRADER, ~/yILGA~ (,_ ~F,Q~ and S/~[.(J`r ~f, /~/~2,b / the Testator and the witnesses, respectively, whose names are signed to the attached or foregoing instrument, being first duly swom, do hereby declare to the undersigned authority that the Testator signed and executed the instnment as his Last Will and that he had signed willingly and that he executed it as his 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 his/her ]mowledge the Testator was at that time eighteen years of age or older, of sound mind and under no constraint or undue influence. ~iNl~.Ti /ifi i ,Cy/~2'.CC~7/ ROBERT A. BRADER Witness ~ Q,l'C ~ ~o'~ Wi ess~ Subscribed, swom to and aclmowledged before me by ROBERT A. BRADER, Testator, and F1)~~ rr YYI'~~cr(~,CS and ~5'f3t! 4' ~ ~1/f}2~/ witnesses, this /ate' day of /~L/.lLCA.vK.(12L, , 1997. ~ii^-.i^J ~-l~L~-<<r ~rc„ Notary Publ' ~~- NOIA'R1A-C-SFAL ____ ? NINA JUNE DAVIS, Notary Public ... { McCoymmssionExuirese0ct 31,1998 1am6er PennsylvanlaAssociation of Notaries 10 IN RE: ESTATE OF ROBERT A. BRADER, Late of the Borough of New Cumberland IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION NO.21-08-0895 RENUNCIATION AND CONSENT OF MANUFACTURERS AND TRADERS TRUST COMPANY Manufacturers and Traders Trust Company, successor to the Dauphin Deposit Bank and Trust Company, Trustee of the Trust created in Article IV of the Will of Robert A. Brader dated December I, 1997, renounces it right to serve as Trustee and consents to the relief requested in the Petition to Approve Termination of a Trust. IN WITNESS WHEREOF, the undersigned has caused these presents to be duly executed on this ~,~~~ day of ~i'l~iLdl~Ru , 2009. MANUFACTURERS AND TRADERS TRUST COMPANY: n /~ Name: JANE; F. l ui~-k L= Title: ~}1C~ ~r(eSiDEroT :354033