HomeMy WebLinkAbout11-13-12COURT OF COMMON PLEAS
PENNSYLVANIA , .,
CUMBERI-AND COUNTY,
IVISION
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APPELLANT ' ~' `- '
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ERITANCE TAX APPEAL ~_,
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PETITION FOR INH o
TO THE HONORABLE
JUDGE:
AND NOW COMES the Estate of Helen F. Crouse (e~es`p~seudanent` to the prov~ ons of 72
counsel, Zullinger-Davis, Professional Corporat~Oann,C ~ Rule 10.2-2, from the
Pa. C.S. §9186(a) and Cumberland County Orp
Commonwealth's Appraisement, Disallowance of Deductions and Assessment of Inheritance
Tax and avers in support thereof as follows:
1, The Decedent died August 26, 2011. At the time of her' death she owned
an 85.9008% limited partner interest (the "Decedent's Interest") in Beech
Tree Investments LP (herein "Beech Tree"). h~ivmg an office at
2. Beech Tree is a Pennsylvania limited partnership
6 2 $ (~(~ i4 D ST , Shippensburg, PA 17257.
3, The Decedent's Interest in Beech Tree was properly reported on the
Pennsylvania Inheritance Tax Return (the "Return") on Schedule "C"
thereof. A copy of said Schedule "C" is attached hereto and incorporated
herein and marked "Exhibit A".
4, The "Reported Value" of Decedent's Interest iri Beech Tree was
$3,235,540.
5, Said Reported Value was determined in part by a "V~~dOri~~ that was
prepazed on behalf of the Estate by Mr. Richard S. Grayev of Glen Arbor
2
6.
7
8.
9
Associates. A copy of said Valuation is attached hereto and marked
"Exhibit B".
The Reported Value, as reflected in the Valuation, was based in Part uP°
discounts from net asset value for minority interest and lack of
marketability, as is fully explained and illustrated in the said Valuation.
The Pennsylvania Department of Revenue (the "Department") examined
the Return and issued is "Notice of Inheritance Tax APPrazsement,
Allou+ance or Disallowance of Deda~ched and msazked as t`Exhibrt •C(the
`°Appraisement") a copy of vvh lanation of
Accompanying the Appraisement was the Department's "Exp
Changes" (attached as a part of "E7chibit C"), which reflected an "Assessed
Value" for the Decedent's Interest in Beech Tree as $4,70 nt 9 deb sion was
The Explanation of Changes indicated that the Departm - erate a
based in part on the conclusion that Beech Tree does not op
"legitimate business enterprise:' The result of the Department's actions is
an increase in Inheritance Tax due of $47,979.04 (the "Disputed Tax")•
10. The Estate disagees with the facts and conclusions contained in the
Appraisement and appeals from the imposition of the Disputed Tax, and
submits that the Department is in error in making same'• Some of the facts
and circumstances submitted by the Estate which support the conclusion
that the Department's actions are incorrect (and not supported by lave) are
as follows: licable Pennsylvania
a. Beech Tree was properly formed under app
law and has its own Federal Employer Identification Number.
b The overall purpose of the partnership (Beech Tree) is to pool
together the partners' resources as co-owners in a form of business
organization having the specific chazacterist:ics of Beech Tree, so
that said resources can be more effectiveTy°fit derived from,eand the
a business to the end of increasing the P rovide for continuity
value of, such resources as a whole, and to' P ,I,he specific
and orderly succession of management.
3
characteristics of Beech Tree which have motivated tike partners as
co-owners to engage in this business include the following:
~1) the ability to conduct business as co-owners without an
entity level income tax; eneral
~2) the ability to sepazate management control in the S
partnership interest from the bulk of eq'uitY ownership
represented by the limited partnership interest;
~3) the ability to help protect the Partnership's Property from
the creditors of the various partners throngll the mechanism
of such creditor having the status only of ~m assignee of an
interest;
~4) the ability to limit the liability of those co-owners who are
limited partners to no more than their capital contributions
or interests;
~5) the ability to decide whether certain transferees onah~mrtaend
partner will be admitted with full ov~niership g rior
thereby to select the individuals witYi whom the p
owners will be in partnership with;
(() the ability to obtain for the general partaner as the managers
of the business, the benefits and burdens of the "busmess
judgement rule" as the basic criterion of management
accountability; arbitration as
~~) the ability to conduct business with mandatory
the mechanism for resolving any business dispute among
the co-owners; the co-
~g) the ability to discourage fnvolous disputes among
owners by requiring the Payment of costs to be shifted to the
non-prevailing party: and
~9) the ability to conduct business among the co-owners while
protecting the confidential aspects of that business from
improper disclosure which harms the business, while
4
providing a mandatory mechanism to resolve any such
claims of harm; and Crouse had contributed a
(10) Limited Partner Helen F•
substantial amount of Allied Irish Bank cometo~eo 'mited
a then current value of $10,000,000. to reduce the
partnership provides a mechanism
concentration of Allied Irish stock over a long period of
time so as to protect the value of the stock.
c, Accordingly, in light of the overall purpose sis specified, the
partnership was formed to engage in the business of investing in
any kind of property, real or personal, which the; partnership may
deem advisable, specifically including, but not limiting the
generality of the foregoing, bonds, notes, debentures, preferred
stocks, common stocks, interests in general partnership and limited
partnership's interest in limited liability companies, mortgages,
ground rents, real estate (including leasehold as well as fee simple
property), investment trusts, deposited or co-mingled funds,
commodities and goods, cows, equipment and other tangible
personal property, and any other investment as shall be determined
by the general partner (the "Property„).
d In furtherance of the business and purposes of the partnership, the
partnership may acquire contributions of property by the partners,
by purchase, by lease, by investment of partnership funds, or
otherwise, real property, interests in real property, personal
property, and interests in personal property, whether owned
directly or indirectly, and wherever situated, and may own, hold,
improve, lease, exchange> transfer or otherwise dispose of such
properties, and the partnership would entE:r into such contracts,
agreements, ventures or arrangements with other Partnerships, joint
ventures, corporations, trusts, associates, individuals, limited
liability companies, or other entities as may be deemed necessary
5
by the partnership to accomplish any of its purposes, whether or
not the term of any such agreement, contract, lease or arrangement
may extend beyond the date of this partnership.
e Other limited partners as well as the Deceder.~t made initial
contributions of capital and limited partner interests were issued
pro-rata based on those contributions• to limited pzutners were pro-
f, All distributions from the partnership
rata, in strict conformity with respective capital interests.
No partnership assets were used for personal expf:nses or purposes
g•
of the Decedent. ~•tnership, retained
h The Decedent, after contribution of capital to P ' ort her
more than enough assets and sources of income to supp
anticipated costs of living for more than her life expectancy
i. All partnership assets were titled and held in partnership name.
Decedent did not hold any General Partner interests nor did she
l~ owers after C1 ~'~_.pbeR ° 2008,
exercise any management p
and the previously owned interest in the General Partner was sold
for a fair mazket value price.
ra s via this Appeal that your Honorable Court
~ WITNESS WHEREOF the Estate P Y 3 roviding that the correctness of the
issue an Order (as provided in 72 P.S.§9186(a)( )) P
Department's actions complained of herein be determined at the Audit of the Account of the
Personal Representative, or at a time the CO Respectfully Submitted,
Hamilton C. Davis, Esquire ,
7
el R. Zullin ,Esquire
rofes;;iona Corporation
ullinger-Davi ,
20 East Burd Street, Suite 6
p.O. Box 40 PA 172`7
Shippensburg,
(717)532-5713
6
VERIFICATION
Executor of the Estate of Helen F. Crouse, verify that the
I, JEAN C. RITCHIE, eel, are true and correct to the
statements herein made in this Petition for Inheritance Tax APP
best of my knowledge, information and belief. I understand th ~ fal~fswom falsificationsato
made subject to the penalties of Pa. C.S.A. §4904, relating
authorities.
~,~, 2012
Dated: Ole
an C. Ritchie
7
REV-1504 EX r (8-98)
C~~HERRANCE TAX RErURN~w
RESIDENT DECEDENT
SCHEDULE C
CLOSELY•HELD CORPORATION,
PARTNERSHIP OR
SOLE•PROPRIETORSHIP
;,ROUSE ~~ ~~y~perNelship Ingest of the decedent other Ihen a
htfortnetbn) must be attached fa each closely d~orshlps.
Sdiedule C-t or G2 (tr~luding all supportlng illfonnetbn M be submM~d for sole-Prop VALUE AT DATE
sote{~IOPdetorship. See instrudbre forthe supportlng OF DEATH_
ITEM V°~~^'~ """ rtnersntp
UMBER o in Beech Tree Investments, LP, a limned pa
t Decedent's 85.90Q8 /o ownership 586.67
that owns primarily marketable securities, held in Investment Account #0502 wi
Orrstown Financial'AdvisoA d scounted va nation of the dehceden~Ys interest ha3 been
(see valuation attached). attached). The fair market value of the
prepared by Glen Arbor Associates (with copy
teen Arbor Assoc ales s $37,666.00 x185.9008%nor $3 235,540 OOunted valuation o
ExKr~T ~ ~
3,235,540.00
vbt. J LVL 7•'iJnnl CVIIII~CI V0.Y1~
April 30, 2012
na• tU[y r. to[)~
Ms. Jean Crouse Ritchie
Mr. James R. Crouse
Co-Executors of the Bstate of Helen F..Crouse, Deceased
C/o Joel Zullinger, Esquire
19 North Main Straet
Chambersburg, PA 17201
Dear Ms. Ritchie and Mr. Crouse:
You have asked us to prepare a valuation (the "Valuation")
of the fair rttarket value of a limited partnership interest (the
"Interest ) in Beech Tree Investments LP, a limited partnership
that owns'/primarily marketable securities (the "]?artnership")-
This valuation is as of August 2hereinlreferredt1`.o asMthe
Grouse's death (such date being
"valuation Date"). It is valid for the Valuation Date only and
for the sole purpose of supporting estate tax returns filed by
the executor's of the Estate. This report is not to be used for
any purpose other than that stated.
Limiting Conditions
In preparing the Valuation, we have relied on (i) financial
information 'provided by management of the Partne:rahip for the
years ended December 31, 2006 through 2010; (ii) various
financial information prepared by Orrstown Financial Advisors as
of August 26, 2011; and (iii) a copy of the Limi.Ced Partnership
Agreement of Beech Tree Investments, Limited Partnership (the
"Partnership Agreement"). We accept no responsj.bility for the
accuracy or the completeness of the information provided to us.
Standard of Practice
Glen Arbor Associates ("GAA") is a business valuation firm
regularly engaged in the valuation of closely-held businesses and
significant interests therein. This report was prepared by
arehattachedraseAppendixdlnt•NeitherreGAAnnorlany ofhitsnofficersd
or employeeis has any interest in the Partnership, and all of such
persons arp independent with respect to the valuation discussed
430 Glen Arhor Court • long of Pruesla, PA 18406 ~~~ ~~ ~~
Phone: 810-265.7A44 • Fez: 610-2652043
Ms. Jean Crouse Ritchie
Mr. James R. Crouse
Co-Executors of the Estate of Helen E. Crouse, Decease
April 30, 2012
Page :?
herein. GAA's compensation for services rendered is not
contingent on any action or event resulting from our opinion.
The Valuation has been prepared (i) pursuant to the standard
of value prescribed by Revenue Ruling 59-60 of the: Internal
Revenue Service and (ii) in conformance raiserseandhthe Uniform
standards of the American SocraisalfPractice of the Appraisal
Standards of 8rofessional App
Foundation.
Aefinition of Eair Market Value
Eair maz!ket value is the price at which the Interest would
change hands between a willing buyer and a willing seller when
the former is not under any compulsion to buy and, the latter is
not under any compulsion to sell, and both parties are able, as
well as willing, to trade and are well informed aibout the
Partnership wind the market for the Interest.
The Partnership
The Partnership was formed on March 2, 2005 and exists
pursuant to the terms of the Partnerseneragrpart~nerbythed"General
American Beech Investments, LLC, as g
Partner ), and Helen F. Crouse, Jean C. Ritchie, Philip M.
Ritchie, Tace Crouse , and James R. Crouse, as limited partners
(the."Limited Partners"). As of the Valuation Date, the General
Partner owned a 18 interest in each material item of income,
gain, loss, deduction or credit of the Partnership and the
Limited Partners owned a 99~ interest in each material item of
income, gain, loss, deduction or credit.
The ownership of the Partnership as of the Valuation Date
was as follows:
Percentage ownershi
General Partner 1.0000$
American Beech Investments, LLC
Limited Partners 135.9008$
Helen F. Crouse Ritchie 6.5496
Jean C. and Philip M. 6.54968
James R. and Tace Crouse
10 0
i. v• IVL/ it LV/JI
vv yr Jig LoiL /.~/~"^ Luiiiub°~ uu•iu
Ms, Jean Crouse Ritchie Deco°ased
Mr. James R. Crouse Helen F. Crouse.
Co-ExecutozQl2f the Estate of
APril 30,
Page 3
The term of the Partnership c°mmenced on March 2, 2005 and
shall continue indefinitely until dissolution and termination
pursuant to the Pennsylvania Revised Uniform Limited Partnership
reement. Limited Partners have
Act or by any pzovisions of the Ag
no right to take part in the management or contro:L of the
Partnership or its ~ayineAlladecisionsswithtrespect to theind the
an any ~s business are to be made by the
Partnership
management of the Partneran~Pperiod when there is more than one
General Partner. Duzing
general partner, the General Partners must act unanimously, an
no general partner has the authority to manage or control the
Partnership alone.
No Limited Partner may assign an Interest in the Partnership
other than as permitted by the Partnership Agreennent. A Limited
Partner may transfer all or a portion of his/her Interest in a
Permitted Transfer provided that the Interest ho:Ldez obtains
written consent °=easonGorefor nor reason at1a11 Zsent may be
withheld for any
The Partners'hi 's Assets
As of the Valuation Date, the Partnership's'. primary asset
consisted o~ investments in marketable securities.
Financial Review
Exhibit 1 searsfendedtDecemberc3l5h2006fthroughPDecemberl3l,
for the fiscal y 2011, Inasmuch as the Partnership's
2010 and as of August 26,
purpose is to acquire, manage, and sell various investments,
there are no operating statements.
Valuation al sis
As discussed proflcashyand investmentsipnL;marketablessets
consist exclusively the principal methodology that we
securities. Consequently, roach.
employed tp value the Interest was an asset app
the net asset value ("NAV") method, the fair mazket
To ap~ly restating the
value of t e Partners' capital was estimated by
partnership's balance sheet as of the Valuation Date to current
Oct. 31. 2012 9:49AM zullinger-davls
No.IUZy Y. 29/91
Ms. Jean Crouse Ritchie Deceased
Mr. James R. Crouse
Co-Executors of the Estate of Helen F. Crouse,
April 30, 2012
Page 4
market value. The indicated fair market value fox a 10
was obtained
interest in the Partners' capital of the Partnership
by deducting the fair market value of the Partnership's
liabilities from the fair market value of its assets. See
Exhibit 2.
The marketable securities were valued at $5,.351,771• This
amount represents the value of oTYStowneFinancialcAdvisorsof the
Valuation Date as reported by
Liabilities of $0 were 2nOliuded in this valuation at their
book value as of August 26,
The NAV is calculated on Exhibit 2. Based on .this method,
ofethelPartnershiplon afcontool marketablenbasis~~astofrAuquapi261
2011 was $5,982,597, or $54,826 per 1~ interest. See Exhibit 4.
Minorit Interest Discount
Since the purpose of this valuation is to provide an opinion
of the fair fiarket value of athenconcludedivaluemfrom thetNAVship
interest in the Partnership,
method, which is a controlo~iagL~~~easpartnex~taacontrolatheste
to reflect t'he inability interest discount").
disposition of the assets ( minority
In order to quantify the magnitude of the .appropriate
minority in>~erest discount, we performed an ana:Lysis of the
relationship between stock prices andclosedsend investmentsfunds
for publicly traded, general equity,
numbertof s~ares1outstandingnasknewuinvestment dollarsnareaaddede
closed-end funds are publicly traded andicing offthedsha esrisf
shares outstanding. As a result, the p
not equal tb the underlying net asset value, as is the case with
mutual funds.
General equity funds were selected because: the Partnership's
marketable 'securities are primarily investments in public
equities.
Exhibiit 3 contains net asset value per share, market
pzicing, ar?d the Prey- fundssasuof,the valuationeDatelueWeor
fifteen general equity roup
calculated'a median discount from net asset vaaue for the g
Uct.31. ZUl! 9:49AM tullinger-davis
NO, IULy Y. 1U/]I
Ms• Jean Crouse Ritchie Deceased
Mr. James R. Crouse Crouse,
Co-Executo~sOlZf the Estate of Helen F.
April 30,
Page 5
of g.q~, In our judgment, 8.4~ is an appropriate discount by
which to adjust the control marketable per interest value to
arrive at a minority marketable per interest value:.
Applying this discount, results in a calculated vSeeeExhibit
interest on a minority. marketable basis of $50,2:_1.
4.
Impact of Illiauidi~
Our
interest,
indicated Partners' caP~rke~able
repiresents a minority
'the lack of a market for the
of 350,221 per 1~
value and needs to be
Interest.
adjusted for
In assessing the appropriate discount to rei:lect such lack
of marketability, therefore, we look to the stud:Les of diublicts
from freealy traded valuesshou dfyieldsardisco nt~thatoshould be
companies 'The analogy
no lower than the median discounts recorded since liquidity in
ears; liquidity for the
those cases is assured within two y
Interest ca{het Partnership snmanagement th tethezeaisenoecurrent
advised by / in the near future.
intention of liquidating the Partnership
All of the summaries of the studies cited i.n footnote 1
re-IPO
enable oanies inawhichcrestricted stockZwasnsoldadand thekpt o
the comp
study differentiated between sales (in which money changed han s
Maki~1g the intuitive
and options (where no cash was involved)• earlier stage
assumption that restricted stock of the sn`uirerthe largest
and more thfi.nly traded companies would req ield the
discounts, the published summaries of such studies y
following analysis:
xThree'such studies, chosen far this report because of the
availability of detail in their presentation, are
9211 Cong. 1st
Insti utional InvestoH.RtuDoc~eNost64£ PartSScurities an
Exchan a Commissio2444-2456; Moroney, "Most Courts Overvalue
Sess. (1971), PP• Taxes (March 1973), PP- 154 - 5'
Closely Held Stocks",
Emoryy "The Value of Marketability BusinesstValuationlNewsa
Public Offerings of Common Stock , December
March, 1994,
and Business Valuation Review, Seecember 1992'
1986, J- un 1888, December 1990,
and December 1995, and September 1997.
No. l UlN
Uct.31. 2U1'i: 9:49AM zullinger-davis
Ms. Jean CrouCTO sechie Deceased
Mr. James R.
Co-Executors of the Estate of Helen F. Crous ,
April 30, 2012
Page 6
SEC Institutional Investor study (1971)
T pe of Com an
OTC (Non-reporting)
$100,000 or less revenues
N, j~/il
Weighted Average Discount Per
End of Rance
55~ (38 of 112)
58~ (18 of. 66)
Moroncy study (March 1973)
Purea~er
Bayrock Growth Fund
Diebold Venture Capital Fund
Enterprise Fund
New America Fund
ValueLine Development Capital
ValueLine Slpecial Situation 'Fund
Discount at U er End
Average
of the Ran e
66~ (1 of 4)
37~ (2 of 6)
75~ (3 of LO)
54~ (8 of 32)
55~ (9 of 35)
51~ (10 of 38)
ecember 1995)
Robert aaird & Co. Studies (Deoetnbor 1992 - D
i count from 2P0 Price
T e,of Transaction
Sale prior to IPO
Average D s _
46~ (43 sales)
The fcregoin studies are by no means the only ones dealing
with this subject, However, the results cited, above are
believed to be representative. Based on the studies cited, the
tradedavaluaesofuthefstockcof f marketability from the freely-
ZThe dames of the selected Funds indicate that they invest
in the shares of smaller, early stage companies rather than
established market performers• Valuin a Business, 3d ed.
3See Pratt, Reilly & Schweihs,
(PP~ ',335 - 348) .
-- No, lUZ9 Y. 3Y/il
Uct.31. 'lU17. 9:49AM zullinger-davis
Ms. Jean Crouse Ritchie
Mr. James R. Crouse
Co-Executo2s012f the Estate of Helen F. Crouse, Decease
April 30,
Page 7
(i) a growing company with proven management,
(ii) that is weaker and less well known than larger
public companies,
(iii) does not pay a dividend and where small blocks
of shares have no control, and
(iv) will have to be held for 2 - 3 years before
full marketability,
would eed scauntsbcitednaboveand 75~, with a median of 55~ of the
averag
Contrasteectationsthat the~Interestzwillabecomezpubliclyno
reasonable eXp the Interest can be convertedwe
traded or re$eemed; accozdingly, Rowever,
into cash on~-y upon liquidation of the Partnership.
have been ad~rised that there is no intention of liquidating t e
Therefore, we are of the opinion that a 25~
partnership. mazketable
discount to k.he indicated Partners' capital minozitY
er intezest is appropriate. Application of
value of $50',221 p er inte:rest of 537,666.
that discount yields an indicated value p
The calculatlions are set forth i.n Exhibit 4.
opinion of Value
Based Qn the foregoing, it is ouruSPi26,n20h1.1twaseS371666
market value of the Interest as of Aug
per Interest.
Sincerely,
GLEN ARBOR 'ASSOCIATES
Q~~ 1~~
By' Gra ev
Richar S. Y
Presid@nt
- _ No. 1019 Y. 33/91
Uct,31, 1Ul;i 9:hUAM zullinger-davis
AppErmsx I
RICAARD S• GRAYEV
Professional Exp e~{ience
- Present President, Glen Arbor Associates
2007
gain of Prussia, PA
sf
of business entities and bsotio
~
n
provide valuations
}on with acqu
corporate securi
dslitigationt
an
estate planning
~P'ice President, Compass Capital Partners, Ltd.
1998 - 2007 ~tadnor, PA
provide services to middle market companies, specializing
and blocks of corporate
~n valuations of business entities
with acquisitions, estate
securities in connection
planning and litigation.
Valuation Services, Curtis ginanoial Group, Inc.
1994 - 1996 'Director,
iphiladel hia Pp+
forming and directing ~rafiraiaa
in
s
Y
g
d
ess
Responsible for
investment banking
division of start-up
f middle market companies-
the needs o
1994
Senior Manager, Arthur And@rsen s Co.
1990 - Philadelphia
Responsible for leading the Valuation Services Group lible
business and intang
the Philadelphia office performing
asset valuations.
1976 - 1990 Senior Manager, Coopera & Lybrand
Phil~lphia, PA
performed financial a
ld companiesaandeintangible assets
he
medium sized closely^
shareholder value concent:ra
chemical,
to increase
roducts,
distribution, consumer p
i
ng,
manufactur
financial services and healthcare.
professional filiations and Activities
Pennsylvaniarofessional seminarsyon valuationc~ssuestand estate
gpeaker at p
planning for business owners.
Edu~atio='
BS ElactKical Engineering, Autgers University. '1967
MBA, Dre#cel University, 1978
Certified Public Accountant, 1980
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Oct. 12. 2011: 10:12AM
BUREAU OF INDIVIDUAL TAX65
1NMERITANCE TAX DIVIHION
PO e0X 2a06o1
w1RRISBVRg PA 171zg•e4¢1
JOEL R ZULLINGER
STE 200
14 N MAIN ST
CHAMBER58URG
zullinger-davis
NOTICE OF INHERITANCE TAX
APPRAISENENT, ALLOWANCE OR DISALLOWANCE
OF DEDUCTIONS AND ASSESSMENT OF TAX
' ~ RETAIN LOWER PORTION FOR YOUR RECORDS_ F ___________________
CUT ALON6_ THIS LINE _~____________________ _•-• --- --•- -
REV-1547 EX AFP C12-1~1DISALLOWANCENOFRDEDUCTION3 ANDRASS ES•SNENTAOFOTAXCE OR ,
~~ ..~ un .9I I7-n926 RCN: 101 DATES 09-17-2012
ESTATE OF: CROUSk ncc ~.. - --
TAX RETURN WAS: ( ) ACC6PTE0 AS FILED C
_____.... ..~~.•nu
APPRAISED VALUE OF F
1. Real. Estate (SCh
2. SC¢¢KE and Bonds
3. Closely Neld SS¢
4. Mort as pee/N¢ios
5. Gesn/dank Doposf
6. Jointly Owned pr
T. Transfers CSch o<
(1) .00
(z) .00
cs) 4.709,597.26
(4) .00
(s) 43,152.95
[g) .00
DATE 09-17-2012
ESTATE OF GROUSE HELEN F
DATE OF DEATM 08-26-2011
FILE NUMBER 21 11-0926
COUNTY CUMBERLAND
ACN 101
APPEAL DATE: 11-16-2012
(Su reverse side under ObJecNons)
pA 17201-1814 A~ount Roeittod~
MAKE R.EGLSTER OFB WILL SD RENI7 PAYMENT T0:
1 COURTHOUSE SQUARE
CARLISLE PA 17013
RASED ONE
A)
6)
:le B)
»rship Interest (SCAedule W
ole CS¢A edu le D)
. Perao nsl Property (gehadulo E)
Cgeho dUl~ F)
g_ Total Assets '
APPROVED DEDUCTIONS 1~ND EXEMPTIONS: .••~.'•~~~• ~'"
.:
9. Funo ral Expanses/ dm. C¢sta/Niho. 6xpanaas (Schedule H)
lg. Deh is/Mortgage Liabilities/lions (S ehadule I)
(y) 98.930.43
(lg)~~1.134.00
(13) 120,064.43
6
11. Total Deductions - (12) 9.234.121.9
12 NaL Value of Tax `;aturn, I-~c?,002 76
.
15 iCaDle/eoyorn~nental ~B e9ues ts:~ Non-eleetod 9115
Ch Trusts (Sohedu la JI ~1~) x
119.20
367
.
14 ar
Nat Value of Es tae Subieot. to Tax ,
.
. assesslFent was issued previously,
f linos 14, 15 and•/Dr 16r 17, 18 end 19 Will
NOTE: an
I
Include the total
h of ALL returns assessed to date.
at
reflect fioul~es t -
"..-JCS3E'SSMENT"OF-T'A7(. "-"~'' C19) ,00 X 00 = -00
15. Amcunt oP Lina 1G at Spousal rata
X 045 =
(16) 7.367.11+~,2R
331,520
16. Amount of Line 1W taxable at Lineal/Glees A rata ,
) nn X 12 = .00
17. 4mount of Line SW at Sfblfn9 rata (1T
00 x 15 .00
18. .
Amount of Line 19 taxah le ai collateral/Class H rate C1 a) (197= 331.520.36
19. prlnelpel Tax Duo
fAX CREDITS:
PAVNEN7 RE PT I DUN7 (*) AMOUNT PAID
DATE NUME6R INTEREST/PEN PAID [-)
1I-22-2011 C 5 1 .17 .D7 69, 5
TnTAI TA
LNTEREST IS CNARGEDiTHROUGH 10-02-2012
AT THE RATES APPLTC~(BLE AS OUTLINED ON THE
REVERSE SIDE OF THI$ FORM
N IF PAID AFTER DATE IN icATED. SEE REVERSE
(7) 4,601,436.18
NDT6: To ensure prop or
credit to Your account.
8uDm1t the upper portion
of this form with your
tax payment.
(g) 0.354.186.39
IV O. UYI] r• I'
~ ~ I~ ~ ~~
~nnsylvania .
DEPAffYMENY Of REVENUE
REV-1547 E7( (L -11)
DUE I 48,
2
`~.E
IF TOTAL DUR-IE RGFL6cT6b-AS A-^cR¢DIT•• (CR)_ VDU nAV 86 DUE
~[L TAX DUE 47,
NTEREST AND PEN. 507.
wo. uyr3
Oct. 12, 2012 10:12AM zullinger-davls
0.EW,00 pf 1040)
~ pei'111Sy~Va!111d iNHERiTANCe rax
DEPARTIMENT OF REVENUE EXPLANATION
' OF CHANGES
BUREAU OF fNONIOUAL TAXES
r. t
PO Boa 480801 _ _
Helen F. Crouse
ITEM
SCHEDULE NO,
B. BelskeY
2111.0928
101
EXPLANATION OF CHANGES
C
Assessed at $4,709,597.26.
value,~~ d ng history,lovelrall finanicial condftionugeneral econom a outlookeana oens set
relevank factors.
woulde~atabl sh the valuecfor the refe eoced estatehs interest n the'above mentioned
compaFhY•
Since t is partnership is comprised of liquid assets, the Beech Tree Investments, LP is
determ ned to be a family investment company, and ae such, non-controlling minority
interes and IacK of marketability discount are not applicable when a family partnership
does nbt operate a legitimate business enterprise.
Pleaselsee Berry Estate 27 Fiduc. Rep. 2d 219.
Held: (Arphans' Court of Venango County agreed and Commonwealth Court affirmed.