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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
IN RE: .
ORPHANS' COURT DIVISION
ESTATE OF HELEN F. GROUSE, l ~
DECEASED N0.21~=0926
ANSWER TO PETITION FOR INHERITANCE TAX APPEAL
TO THE HONORABLE JUDGES OF SAID COURT:
AND NOW, this 20t" day of December, 2012, comes the Commonwealth of
Pennsylvania, Department of Revenue, through its Office of Chief Counsel and by its Senior
Counsel, Lora A. Kulick, and respectfully responds to this Petition as follows:
1. Paragraph one is admitted.
2. Paragraph two is admitted. ~ o :~ ~ ~
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3. Paragraph three is admitted. ~ ,~~,. ~ ~ ~ d
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4. Paragraph four is admitted. ~'~ ~, ''~ ~~ c~ ~
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5. Paragraph five is admitted. ~=~' ~~~~ `-~ ~
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6. Paragraph six is admitted. ~'? ~'
7. Paragraph seven is admitted.
8. Paragraph eight is admitted.
9. Paragraph nine is admitted.
10. Paragraph ten contains conclusions of law to which no responsive pleading is
required under PA. R.C.P. The same therefore are denied. Furthermore, Paragraphs ten a j are
denied. The Department is without knowledge or information sufficient to form a belief as to the
purpose of the partnership or its specific characteristics' motivation to the partners; the purpose
for which it was formed; how it operated; whether contributions or distributions were made; how
partnership assets were used; whether decedent retained assets to support her costs of living; how
all partnership assets were held; when decedent exercised any management powers; or any other
operations or specifics of the partnership. Specific proof is demanded.
WHEREFORE, the Commonwealth of Pennsylvania, Department of Revenue
respectfully requests that this Court deny the Petition and sustain the Department's assessment in
full.
Respectfully submitted by,
Lora A. K c
Attorney for Respondent
PA Department of Revenue
Office of Chief Counsel
P.O. Box 281061
Harrisburg, PA 17128-1061
Attorney I.D. No. 69436
COMMONWEALTH OF PENNSYLVANIA :
ss
COUNTY OF DAUPHIN :
The undersigned, being duly sworn according to law, deposes and says that he is a Trust
Valuation Specialist in the Inheritance Tax Division of the Bureau of Individual Taxes for the
Commonwealth of Pennsylvania, Department of Revenue, that he is authorized to make this
affidavit on its behalf, and that the averments of the foregoing are true and correct to the best of
his knowledge, information and belief.
Brian H. Belske
Sworn to and Subscribed before me
thisay of,~~012
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
I1V RE:
ORPHANS' COURT DIVISION
ESTATE OF HELEN F. GROUSE,
DECEASED N0.2122-0926
CERTIFICATE OF SERVICE
I hereby certify that I am this 20th day. of December, 2012 serving a copy of the foregoing
document upon the person and in the manner indicated below, which service satisfies the
requirements of Pa. Orphans' Court Rule 5:
SERVICE BY FIRST CLASS MAIL
ADDRESSED AS FOLLOWS:
Hamilton C. Davis, Esq.
Zullinger Davis, PC
14 North Main Street
Suite 200
Chambersburg, PA 17201
Lora .I
Attorney for Respondent
PA Department of Revenue
Office of Chief Counsel
P.O. Box 281061
Harrisburg, PA 17128-1061
Attorney I.D. No. 69436