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HomeMy WebLinkAbout08-03-09COMMONWEALTH y~F PENNSYLVANIA DEPA~tTMENT OF REVENUE BUREAU OF INDIVIDUAL TAXES INHERITANCE TAX DIVISION PO BOX 280601 HARRISBURG PA 17128-0601 ~~~NHERITANCE TAX `'-'-~' . -_ _ ~.; ` aE-CORD ADJUSTMENT QRPH~1N'S ~f~JURT RICHARD L WEBBER JR ~~~t~~~,~,"~ ~ ~ P~ WEIGLE ~ ASSOCIATES 126 E KING ST SHIPPENSBURG PA 17257 REV-1593 EX AFP CO1-09) DATE 07-24-2009 ESTATE OF MAINS PAULINE A DATE OF DEATH 07-25-2007 FILE NUMBER 21 07-0727 COUNTY CUMBERLAND ACN 101 Amount Remitted MAKE CHECK PAYABLE AND REMIT PAYMENT T0: REGISTER OF WILLS CUMBERLAND CO COURT HOUSE CARLISLE, PA 17013 NOTE: To insure proper credit to your account, submit the upper portion of this form with your tax payment. CUT ALONG THIS LINE ~ RETAIN LOWER PORTION FOR YOUR RECORDS ~ --------------------------------------------------------------------------------------------------------------------------------------- REV-1593 EX AFP CO1-09~ ** INHERITANCE TAX RECORD ADJUSTMENT ** ESTATE OF MAINS PAULINE A FILE N0. 21 07-0727 ACN 101 DATE 07-24-2009 ADJUSTMENT BASED oN: PROTEST BOARD DECISION VALUE OF ESTATE: 1 . Real Estate (Schedule A) (1) 120, 000.00 2. Stocks and Bonds (Schedule B) (2) 1 , 512, 482.71 3. Closely Held Stock/Partnership Interest (Schedule C) C3) .0 0 4. Mortgages/Notes Receivable (Schedule D) (4) .0 0 5. Cash/Bank Deposits/Misc. Personal Property (Schedule E) (5) 330,919.98 6. Jointly Owned Property (Schedule F) C6) .0 0 7. Transfers (Schedule G) (7) .0 0 8. Total Assets (8) 1 , 963, 402.69 DEDUCTIONS AND EXEMPTIONS: 9. Funeral Expenses/Administrative Costs/ Miscellaneous Expenses (Schedule H) (9) 85,113.30 10. Debts/Mortgage Liabilities/Liens (Schedule I) (10) 5,34 7.0 6 11. Total Deductions C11) 90,460.36 12. Net Value of Tax Return C12) 1 , 872, 942.33 13. Charitable/Governmental Bequests; Non-elected 9113 Trus ts (Schedule J) C13) 25,0 0 0.0 0 14. Net Value of Estate Subject to Tax C14) 1,847,942.33 TAX: 15. Amount of Line 14 at Spousal rate (15) . 00 X 00 = . 00 16. Amount of Line 14 taxable at Lineal/Class A rate (16) 1 , 847 , 942. 33 X 045 = 83, 157 .40 17. Amount of Line 14 at Sibling rate C17) . 00 X 12 = . 00 18. Amount of Line 14 taxable at Collateral/Class B rate C18) .0 0 X 15 = .0 0 19. Principal Tax Due (19) 83, 157.40 TAX CREI]TTS: DATE NUMBER INTEREST/PEN PAID C-) AMOUNT PAID 10-24-2007 CD008847 2,368.42 45,000.00 04-28-2008 CD009628 .00 18,707.49 08-29-2008 CD010215 .00 10.78 09-24-2008 CD010318 10.78- 17,081.49 BALANCE OF UNPAID INTEREST/PENALTY AS OF 09-25-2008 TOTAL TAX CREDIT 83,157.40 BALANCE OF TAX DUE .00 INTEREST AND PEN. 498.45 TOTAL DUE 498.45 * IF PAID AFTER DATE INDICATED, SEE REVERSE C IF TOTAL DUE IS LESS THAN S1, NO PAYMENT IS REQUIRED. FOR CALCULATION OF ADDITIONAL INTEREST. IF TOTAL DUE IS REFLECTED AS A "CREDIT" CCR), YOU MAY BE DUE A REFUND. SEE REVERSE SIDE OF THIS FORM FOR INSTRUCTIONS.) <.~ BOARD OF APPEALS P o Box 2s1o21 HARRISBURG, PA 17128-1021 RICHARD L WEBBER JR ESQ WEIGLE & ASSOCIATES PC 126EKINGST SHIPPENSBURG, PA 17257 r ~ I~r'1S ~.1/~nl~ ~ p~ Y DEPARTMENT OF REVENUE BOARD OF APPEA~5 IN RE ESTATE OF: MAINS PAULINE A DOCKET NO, TAX TYPE APPEAL TYPE FILE NUMBER: ACN APPRAISEMENT: PETITION FILED EXAMINER: 0904409 Inheritance Protest 2107-0727 101 1/5/2.009 2/24/2009 SHAWN E. YOUNG Direct Dial: (717) 783-7894 Fax: (717) 787-7270 shyoung@state.pa.us July 10, 2009 MAILING DATE: DECISION AND ORDER The Department issued an appraisement and assessment dated January 5, 2009, which included interest on the tax due from the delinquent date, April 25, 2008 to the date of payment, September 24, 2008. The Petitioner has objected to the imposition of interest because the estate representative was not aware that the decedent owned additional securities prior to the delinquent date. Petitioner argues that the interest and penalties on the additional tax due should not be charged because the additional tax was paid as soon as the executors became aware of the unreported securities. Section 2143 of the Inheritance and Estate Tax Act of 1991 allows for the adjustment or abatement of interest when the payment of inheritance tax has not been made because of litigation or other unavoidable cause of delay. The term 'Mitigation or other unavoidable cause of delay" is found in existing law and ~ .f r r MAINS PAULINE A Page 2 of 2 BOARD DOCKET NO. 0904409 is interpreted to require good faith litigation arising from an honest disagreement. Husband's Est., 316 Pa. 361 (1934). Since there is no evidence that the decedent's assets were the subject of litigation and since the circumstances surrounding the failure to pay the tax liability in a timely manner do not constitute "unavoidable cause of delay" within the meaning of the Statute, the Board is without statutory authority to grant the relief requested. The Board also notes that no separate penalties were charged. Accordingly, it is hereby Ordered that the protest is denied. FOR THE BOARD OF APPEALS LAUREN A. ZACCARELLI, CHAIR ANY APPEAL FROM THIS DECISION MUST BE FILED WITH THE ORPHANS' COURT WITHIN SIXTY (60) DAYS OF RECEIPT OF THIS DECISION. ANY APPLICABLE NOTICE REFLECTING ANY CHANGES TO THE ACCOUNT PURSUANT TO THE BOARD'S DECISION AND ORDER MAY BE MAILED TO YOU BY THE APPROPRIATE BUREAU . IF YOU REQUIRE THIS INFORMATION IN AN ALTERNATE FORMAT UNDER THE PROVISIONS OF AMERICANS WITH DISABILITIES ACT OF 1990, PLEASE CALL (717) 783-3664, OR FOR SERVICES FOR TAXPAYERS WITH SPECIAL HEARING AND SPEAKING NEEDS: 1-800-447-3020 (TT ONLY}. Board of Appeals { PO Box 281021 {Harrisburg, PA 17128 { 717.783.3664 { www.revenue.state.pa.us