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HomeMy WebLinkAbout04-26-13 IN RE: ESTATE OF ROBERT M. : IN THE COURT OF COMMON PLEAS OF MUMMA, deceased : CUMBERLAND COUNTY, 13ENNSYLVANIA ORPHANS" COURT DIVISION NO. 21-86-398 AUDITOR'S INTERIM REPORT, APRIL 24, 2013 AND REQUEST FOR ORDER To The Honorable J. Wesley Oler, Jr.: Your Honor has appointed me Auditor in the above captioned matter and charged me with reviewing the most recent and final account and proposed distribution in the above matter and holding a hearing on the most recent accounting and proposed distribution. I had held more than thirty-five (35) days of hearings on the objected accounts of this Estate and Trusts created thereunder. The parties had stated following the final hearings that they were attempting to hold meetings and discuss possible resolution of some or all of their respective issues. In the interim certain Petitions were filed which your Honor has referred to me for an interim report. The following report was prepared by me and ready in November 2012, but I had filed a request for interim payment prior to issuing the report. Your Honor entered a recent Order directing payment of my costs and fees and a check was delivered to my office on April 4, 2013. Unfortunately I was out of the country and have recently returned and file this report as written in November-"0 12. c') _ C__ ri C+ R{ C77 ;Z3 C-j r. C., 7 1 The Trustee, Lisa Morgan has filed a two Petitions, the first seeks permission from the court to hire a real estate expert and begin to liquidate the trust's assets including certain real estate assets which the trust has a substantial interest and to terminate or cash-in certain life insurance policies owned by one of the corporations, D. E. Distribution Corporation. One of the reasons stated for the request was to inject the trust with funds to insure ongoing expenses can be paid. The second Petition relates to the proposed sale of real estate. Your humble servant conducted a series of many telephone conferences with the parties' counsel. Ms. Linda Mumma, one of the four children of Robert M. Mumma and a beneficiary of the trust had written to this office, but I did not personally review the contents of the letter. I directed my assistant return the letter to the address from which it was sent and requested Ms. Mumma provide our office with a current address and phone number and further advised her that if she proposed to file an answer to the Petitions of the trustee, she should file the same with the Clerk of the Orphan's Court. Ms. Mumma was advised by mail of the first telephone conference and invited to participate; however, she did not contact this office with a telephone number or a current address. The letters from this office including the Notice of Hearing on the current petitions were sent to Ms. Mumma at the address on the envelope of her initial letter and none were returned to my office by the United States Postal Service. Following our conferences and in the weeks separating each conference, the parties exchanged information and advised that they anticipated stipulating to the facts and only desired legal argument on the issues. The main issues were the authority vested in the trustee to sell certain real estate and the affect of the MRA I and MRA II agreements on the authority of the trustee and the interpretation of the Will's residuary disposition provision and the powers, duty and authority of the surviving trustee. I therefore scheduled argument for July 26, 2012 at 1:00 2 PM and sent notices to all the parties and beneficiaries or their counsel of record. Counsel provided a stipulation of facts to my office two days prior to the argument hearing. The argument hearing was held at 1:00 PM July 26, 2012, in the Courtroom of the Old Courthouse as noticed. During the hearing the parties agreed that the life insurance policies currently owned by D. E. Distribution Corporation would be terminated, proceeds cashed and distributed and therefore, I requested an Order permitting the same. Your Honor entered an Order directing that "Lisa Morgan, in her capacity as President of D. E. Distribution Corporation, cancel, redeem or terminate the life insurance policies owned by D. E. Distribution Corporation, receive the proceeds of the same and hold the proceeds for distribution to all shareholders of D. E. Distribution Corporation according to their respective interest in said corporation. Further that within ten days of this Order, D. E. Distribution Corporation and the residuary trust established by the Last Will and Testament of Robert M. Mumma through their accountants shall provide all counsel with the method and the documents supporting the same for ascertaining the proportional shares each shareholder/party holds in the corporation. Upon receipt of the information each party shall have five (5) days to object and if no objection is made, Lisa Morgan, as president of D. E. Distribution Corporation, shall distribute the net proceeds received from the terminated policies to all shareholders in accordance with his, her or its proportional interest." The undersigned had waited to be noticed as to whether the cancelation and redemption of the life polices had occurred and if it had occurred the amount of funds received, and if redeemed that funds had been received, if the amount of funds received was sufficient to assure continued administration of the Trust. The parties had stated the cash values of the policies were approximately two million dollars. 3 During a recent conference call the undersigned was advised by the trustee's counsel that he had not received the cash value from the respective carriers on the life policies because Mr. Brooks, counsel for Robert M. Mumma, II, had not responded to his requests relative to the matter. Mr. Rinaldo, counsel. for Barbara Mumma, had responded to the inquiry. Mr. Brooks stated he had not received this Honorable Court's Order. The undersigned inquired of the Clerk of the Orphan's Court and determined that Your Honor's Order was sent to Mr. Brook's office via United States First Class mail many months ago and that it had not been returned to the Clerk's office by the postal service. The undersigned had sent copies of my interim report and proposed order by means of electronic mail to all parties or their counsel prior to presenting it the Your Honor. Your Honor's Order directed counsel to exchange the proposed proportionate share distribution and only if a party objected within a short time frame he or she by their inaction was deemed to approve and the trustee could then receive the proceeds and distribute them in accordance with the proportionate shares of interest. Counsel for the Estate and the trusts created thereunder did not report that the trusts were in any immediate need of funding beyond the funds it believed would be received from the cash value of the life policies. The undersigned will address the remaining two issues relating to the proposed sale of the property referred to as the UPS property and also to the trustee's, Lisa Morgan's, request to hire certain experts and begin a plan of liquidation and distribution of the assets of the Estate and the trusts thereunder, to the residuary beneficiaries. 4 THE PROPOSED SALE OF PROPERTY- UPS DRIVE AND REQUEST TO BEGIN PLAN OF LIQUIDATION OF TRUST ASSETS The parties entered into the following stipulation of facts: 1. Lisa M. Morgan is the sole Trustee of the Marital Trust (the "Marital Trust") and the Residuary Trust (the "Residuary Trust") under Mr. Mumma's will. The Will of Robert M. Mumma is attached hereto as Exhibit "A". 2. Respondents Robert M. Mumma II ("RMM II"), Barbara M. Mumma (`Gabs Mumma"), and Linda Mumma ("Linda Mumma") are, along with Mrs. Morgan, remaindermen of the Marital Trust and the Residuary Trust. 3. Robert M. Mumma died on April 12, 1986. 4. Barbara McK. Mumma, widow of Robert M. Mumma, died on July 17. 2010. 5. RMM II and Babs Mumma filed Objections to all of the accounts filed by Mrs. Mumma and Mrs. Morgan. 6. Attached as Exhibit "B" is a Summary of Appraisals, identifying the various parcels of real property in which the Trusts claim interest, either directly or through ownership by the Trusts of interest in various entities, stating appraised values of such real estate as of July 17, 2010, as submitted by an appraiser retained by Lisa Morgan. 7. The Agreement Among Tenants-in-Common known as "MRA-1" lists the following ownership interest: Estate of Robert M. Mumma 81.82507% RMM II 4.24708% Linda Mumma 4.23555% Babs Mumma 4.23555% Lisa M. Morgan 4.23555% Barbara McK. Mumma 1.22120% 5 The MRA-I Agreement is attached hereto as Exhibit "C." 8. The Agreement Among-Tenants-in-Common known as "MRA-lI" lists the following ownership interest: Estate of Robert M. Mumma 98.08612% RMM II 0.47847% Linda Mumma 0.47847% Babs Mumma 0.47847% Lisa M. Morgan 0.47847% Barbara McK. Mumma 0.47847% The MRA-II Agreement is attached hereto as Exhibit"D". 9. Mrs. Morgan, in her representative capacity as Executrix of the Estate of Barbara McK. Mumma, is the sole shareholder, director and officer of Mumma Realty Associates, Inc., (MRA, Inc."). the manager of the assets governed by both the MR,k-I Agreement and the MRA- 11 Agreement. 10. Real estate Mrs. Morgan believes is governed by the MRA-1 Agreement:appears on Exhibit"B" as items 10, 11, 12, 13, 15, 16, 17, 18, 19, 20, 21, 22 and 23. 11. Real estate Mrs. Morgan believes is governed by the MRA-I1 Agreement appears on Exhibit`B" as item numbers 9 and 14. 12. Mrs. Morgan also believes that the Residuary Trust owns two parcels of real estate, set forth as item numbers 24 and 25 on Exhibit "B," and a parcel of real estate in Leadville, Colorado having an appraised value as of$670,000.00, as stated in an appraisal submitted by an appraiser retained by Lisa Morgan. 13. Mrs. Morgan also believes that the Marital Trust claims ownership of real estate known as Pennsboro Center in Cumberland County, Pennsylvania. This real estate is set forth as item number 2 on Exhibit `B". 6 14. D-E's assets consist of at least three parcels of real estate. accounts receivable from various affiliated entities, some tangible personal property, in the form of fully depreciated equipment of minimal value and certain life insurance policies having cash values collectively of approximately $2.033,064.00, Real estate owned by D-E is set forth on Exhibit "B" as items 5, 6 and 7. 15. GAT's assets consist of at least one parcel of real estate and an escrow account held for the benefit of RMM II as a result of a certain lawsuit by RMM 11 asserting dissenters' rights with respect to the sale of certain of GAT's assets. 16. Real Estate owned by GAT is set forth as item number 8 on Exhibit `B'". 17. Mrs. Morgan has advised RMM II, Babs Mumma and Linda Mumma that she "does not intend", as Trustee, to sell or otherwise dispose of real estate, stock or other non-cash assets in the Trusts, the Mumma Realty Associates tenancies, D-E Distribution Corp. or G-A-T Distribution Corp. without seeking and obtaining prior approval of the Orphans' Court. Mrs. Morgan will continue to make expenditures for costs and expenses incurred by the Trusts of the corporate entities, including, without limitation, operating expenses professional fees and taxes." 18. Mrs. Morgan desire to sell two parcels of real estate! pursuant to a proposed sales agreement, which document is attached hereto at Exhibit "E". 19. The Real Estate is contiguous to a parcel of approximately 61 acres of real estate owned by Bobali Corporation (`Bobali Property") the appraised value of which parcel, according to the appraisal performed by the appraiser retained by Lisa Morgan, was $2,300,000. as of July 17, 2010. 20. Gibson Boulevard, in the vicinity of UPS Drive and the Bobali Property, is a divided roadway. 7 21. The remaindermen identified in paragraph 2 hereof are among the shareholders of Bobali Corporation. The Undersigned sets forth the following facts relating to the matters raised by the Trustee as determined from previous hearings and the record of this case as follows: 1. Robert M. Mumma's Last Will and Testament dated May 19, 1982 and his First Codicil to Last Will and Testament dated October 12, 1984 were duly probated with the Register of Wills in and for the County of Cumberland. (Copies previously attached) 2. Mr. Mumma's wife, Barbara McK. Mumma and his daughter, Lisa Morgan were named and appointed as Co-Executrices and also as Co-Trustees of both trusts established in the Last Will and Testament. 3. The Seventh and Eighth sections of Mr. Mumma's Last Will and Testament establish trusts for the lifetime benefit of his wife, Barabara Mck. Mumma. 4. The final paragraph of the Seventh section of Mr. Mumma's Last Will and Testament states: "Upon the death of my said wife, the principal of this Trust, as it is then constituted, shall be paid over by my surviving Trustee unto my children, ROBERT M. MUMMA, II, BARBARA M. McCLURE [ now Mumma], LINDA M. ROTH [now Mumma] and LISA M. MUMMA [now Morgan], free of this trust, share and share alike, per stripes and not per capita." 5. The second paragraph of the Eighth section of Mr. Mumma's Last Will and Testament states: "Upon the death of my said wife, the principal of this trust, as it is then constituted, or, if my said wife does not survive me, upon my death, my residuary estate, shall be paid over by or my surviving trustee or by my successor Executor, as the case 8 may be. unto my children, ROBERT M. MUMMA. II, BARBARA M. McCLURE [ now Mumma]. LINDA M., ROTH [now Mumma] and LISA M. MUMMA [now Morgan]„ free of this trust, share and share alike, per stripes and not per capita." 6. The last paragraph of the Eighth section of Mr. Mumma's Last Will and Testament states: "The Trustees shall be vested with reasonable discretionary powers in all matters not otherwise herein specifically provided, they shall exercise their sound judgment and discretion in the performance of their duties. They shall not be liable for any error of judgment provided that such error is honestly made." 7. The Ninth section of Mr. Mumma's Last Will and Testament details the broad powers granted to the trustees and provides, in part : "as in their discretion they deem advisable, in addition to and not in limitation of their common law and statutory powers: (1) To allot, assign, ... convey,...mortgage, ...sell ... and in general do any and every act and thing and to enter into and carry out any and every agreement with respect to the property included in any trust created under this Will which they could if they were the absolute owners thereof, without being limited in any way by the specific grants of power hereinafter made. (2) ...retain .. all or any part of my property or assets which constitute a part of the trusts... . (3) To sell or exchange, either privately or at public sale and without prior approval of any court at such time or times and at such prices and on such terms and conditions as the trustees may consider advisable all or any part of the trust property ... . 9 (4) To manage any real property held by them in such manner as they may determine, including authority to alter, repair, maintain or improve, ... to erect or demolish buildings thereon. ... and to charge the cost of any action taken with regard to any such property to the principal or income as they may determine. (5) To lease any real estate subject to the Trust ... as may be in the discretion of the trustees in the best interest of the trust estate. (6) To invest ... or acquire ... real or personal property ... as they may deem advisable, ... it being my intention to give my trustees power to act in such manner as they believe to be in the best interest of the Trusts created herein. (7) To pay income tax on gains from the sale ... . (8) To amortize, ... mortgage ... against any real estate [and] ... the trustees shall specifically keep and perform all of the covenants, terms and conditions of any existing mortgage or mortgages upon said real estate ... . (9) To ... exercise all rights and privileges pertaining to securities which are available (10) To receive or make distribution of any trust herein, either in money or in- kind ... The judgment of the trustees as to what constitutes an equitable distribution or apportionment shall be binding and conclusive on the beneficiary hereof. Nothing herein contained, however, shall empower the trustees to make distribution before the time or times specified herein (1 l) To pay ... any claim ... . (12) To use income ... to maintain any policies of life insurance ... if the trustees determine that the best interest of my family would be served ... 10 (13) To employ counsel. ... accountants, ... appraisers ... and others and ... to pay their compensation ... . (14) To borrow money ... . (15) To incorporate ... . (16) To carry on and conduct any business enterprise in which I may be engaged at my death. (17) To hold ... consolidated funds ... as they may determine. (18) As to each Trust created herein, to exercise all the powers granted and all duties imposed herein until such time after the termination of that Trust as the property included in that Trust has been fully distributed and to do all other acts which in their judgment, may be necessary or appropriate for the proper or advantageous management, investment or disposition of any property included in any Trust created herein." 8. The Estate of Robert M. Mumma and/or the trusts created thereunder has a majority ownership interest various parcels of real estate pursuant to two agreements commonly referred to as MRA and MRA II and the real estate subject to the agreements are collectively called the Premises and a list of the parcels subject to the respective agreement are attached as an Annex to each agreement. 9. The MRA I agreement paragraph 1(b) provides that the manager, (Mumma Realty Associates, Inc.), has certain duties, rights and authority, for and on behalf of the Owners and include : to advertise space for rent, to rent space, to collect rent, to institute legal action for delinquent rent, to make repairs, to contract for utilities, to perform services 11 for care, protection and maintenance, to hire, supervise and discharge employees, prepare and file forms. establish and maintain files, review bills and insurance policies, and to maintain books and accounts. 10. The MRA I agreement paragraph 1 (e) specifically states that "... [Ti]o manager (or Owner) on behalf of the owners, without the consent of the Owners, shall have any right or authority implied or apparent : (i) to sell or encumber the Premises or any part thereof or any interest of an Owner therein except as provided in Section 3 below." 11. The MRA I agreement paragraph 3, states, in part, in subsection (b) "Except as hereinafter provided in this Section, no owner shall dispose of, sell, transfer, assign, convey, mortgage, pledge, grant a security interest in, hypothecate or encumber part or all of his or her divided interest in the Premises without the prior consent of the Owners and any such transaction purported to be accomplished contrary to the provisions hereof shall be absolutely void." 12. The MRA I agreement paragraph 4 states: "Action by Owners. General, overall management of the Premises and of all matters arising out of or in connection with the premises, including a sale or mortgage of the entire Premises or a part thereof, shall be vested in the Owners jointly and each owner shall abide by the policies and decisions with respect thereof. Any agreement, approval, decision, consent, request or other action of the Owners shall be by a majority (in interest) vote and in writing unless otherwise indicated.'" 13. The MRA I agreement also provides that any owner has the option to have any dispute resolved before a single arbitrator and all parties to this :matter do not desire binding arbitration on this matter. 12 14. One property owned and managed contains two contiguous parcels of vacant land totaling approximately 2.17 acres located on UPS Drive in Dauphin County and having been designated as parcel number 63-024-102 ("UPS property") was appraised in 2010 at $205.000. 15. Another property in which the parties to this matter have an ownership interest, through their respective interest in the Bobali Corporation, is a parcel of vacant land of approximately 61 acres property and contiguous to the UPS property and having boundaries on both UPS Drive and Gibson Boulevard in Dauphin County ("Gibson property') was appraised in 2010 at $2,300,000.00. (A copy of an aerial photograph of the properties together with a super imposed boundary line provided by the Dauphin County Tax Assessment Office is attached for reference only. The UPS property is outlined and cross hatched in red and the Gibson property in green) 16. Sometime in 2011, Lisa Morgan notified her brother Robert and sisters Barbara Mumma and Linda Mumma that she would be seeking a purchaser for the UPS property. 17. Lisa Morgan had negotiated for the sale and purchase of the UPS property to United Parcel Services, Inc. and/or its affiliate BT-Newyo, LLC for $350,000.00. 18. Lisa Morgan, as trustee of the trusts holding majority interest ownership of the UPS property, authorized Mumma Realty Associates, Inc, the manager of the UPS property, to enter into a purchase agreement with BT-Newyo, LLC for $350,000.00. 19. On April 11, 2012, Lisa Morgan, as President of Mumma Realty Associates, Inc. signed an agreement for the sale and purchase of the UPS property for the offered $350,000.00 contingent on this Honorable Court's approval. 13 20. On May 21. 2012, Lisa Morgan notified her siblings, Robert M. Mumma. II, Barbara Mumma. and Linda Mumma that she had authorized an agreement for the sale and purchase of the UPS property and the terms of the sale. She requested their concurrence and stated that if they did not concur she would seek approval from the Court. 21. Lisa Morgan desires to sell the UPS property in her capacity as a residuary beneficiary. 22. Robert M. Mumma II objects to the sale. 23. Barbara Mumma objects to the sale. 24. Linda Mumma was contacted but she has not communicated whether she consents or objects to the sale, either verbally or in writing. 25. Lisa Morgan, as trustee, desires to begin a plan of liquidation and distribution of the remaining assets of the Estate of Robert M. Mumma and the trusts established thereunder, including the real estate subject to the MRA I and MRA II agreements. 26. Lisa Morgan individually consents to her proposed liquidation and sale of the assets. 27. Robert M. Mumma II objects to the sale of real estate assets or other assets. 28. Barbara Mumma objects to the sale of real estate assets or other assets. 29. Linda Mumma was contacted but she has not communicated whether she consents or objects to any additional sale or liquidation of assets. 30. Robert M. Mumma believes that the remaining assets of the Estate and the trust must be individually separated and that each separated, individual asset must then be transferred to himself and his three siblings as either tenants in common or joint tenants with the right of survivorship. 14 ARGUMENT OF THE PARTIES A. Lisa Morgan Lisa Morgan, as the sole surviving trustee, argues that Section 3351 relating to the powers of the personal representative and the PEF Code Section 3354 relating to testamentary powers to sell real property, supports her position. She also argues that the Ninth Section, paragraph 3 of the Last Will and Testament of Robert M. Mumma grants her the authority as surviving trustee, to sell or exchange, either privately or at public sale and without prior approval of any court any part of the trust property, real, personal or mixed and to execute all deeds, bills and other documents necessary to effectuate the same. She further argues that her siblings, Robert Mumma and Barbara Mumma have no right to insert themselves into her decision making process regarding the disposition of the trust assets as she bears the burden of a fiduciary subject only to possible audit after the fact. She asserts she is not required to seek the Court's permission but is currently requesting clarification based on her previous promises to this Court and the "uniquely contentious environment that surrounds" this matter. In support of her position, Lisa Morgan further argues that the Pennsylvania Superior Court's recent decision involving her administration of this estate rejected the argument by Robert M. Mumma, II that she as trustee was required at the death of her mother to make an immediate, equal, in-kind, distribution of the trust assets to the residual beneficiaries. She argues that this rejection was an affirmation of her authority to make independent decisions relating to the liquidation and equal distribution of the trust's assets. 15 Lisa Moran, as the sole Trustee, argues that she has the authority, as trustee, to sell the UPS property and to sell all the other properties subject to the MRA I and the MRA II agreements without the advice or consent of the owners of minority interests. She bases this on the fact that the Estate is the Owner of more than more than eighty (80%) percent of the Premises and because of the super-majority needs no approval from the other Owners, her siblings, who owns a combined total of less than thirteen (13) percent of MRA I and less than two (2) percent of MRA II. She further argues that this Honorable Court by the Orders and Opinions of the Honorable Harold E. Sheely dated March 24, 1992 and November 5, 1992 at Docket No. 66 Equity 1988, has previously determined that the trustees because of this super majority ownership interest did not need to seek approval from the minority Owners or this Honorable Court. B. Robert M. Mumma II Robert M. Mumma, II first argues that the statements made by the Superior Court in its recent opinion were merely dicta and that its rejection of his many raised issues creates no precedential value. He argues the questions before the Superior Court was whether Lisa Morgan, as Executrix and Trustee of his father's estate and also as Executor of his mother's estate created a conflict of interest and whether Lisa Morgan had breached her fiduciary duty. The issue presented before this Honorable Court and before the undersigned relates to a very specific issue relating to Lisa Morgan's authority to sell estate assets and the interplay between the specific provisions of the Last Will and Testament of Robert M. Mumma and the PEF Code. Robert M. Mumma II next argues that his father's Last Will and Testament granted specifically defined powers and Pennsylvania Courts and the PEF Code support his position that 16 Lisa Morgan power as trustee terminated at the death of Barbara 1VIcK. Mumma, her Co-trustee. He cites the PEF Code's provision relating to events which terminate or partially terminate a trust and their effect on the continuing power and duties of a trustee. 20 Pa. C.S. Section 7780.7. Robert M. Mumma, II further argues that the Pennsylvania Courts have determined the polestar in every trust is the settlor's intent and in every will the testator's intent, is the controlling factor. (cites omitted) He asserts the clear intent of his father was that immediately upon the death of his wife, Barbara McK. Mumma, the trust's assets were to be distributed equally to his four children. Under the governing terms of his father's Will he argues Lisa Morgan is not the sole trustee of any trust as both trusts have terminated by the occurrence of the death of his mother. He claims the original purpose of the trust was to benefit his mother during her lifetime and at her death the purpose ceased and the trust terminated. He argues that Lisa Morgan has no standing or authority to act in any role as a putative trustee. Robert M. Mumma Il agrees arguendo that MRA I is the owner of the UPS property and he absolutely agrees that Bobali Corporation is the owner of the Gibson property. He argues that the UPS property should not be sold because it provides additional access to the Gibson property and that Lisa Morgan did not fully evaluate the effect the sale of the UPS property may have on the Gibson property. He presented no facts and cited no legal authority for his argument. Robert M. Mumma Il: also acknowledges the differing ownership interests but argues, Lisa Morgan's reliance on her ability to control the Estate's ownership percentage, and the voting power associated with it, is misplaced and that she is only entitled to vote the share she owns in her individual capacity. He cites no legal authority for his argument and does not attempt to distinguish Judge Sheeley's findings and determination in this matter at Docket No. 66 Equity 1988. 17 Robert M. Mumma, II finally argues that Lisa Morgan should not be permitted to sell the UPS property because she has not fully explored all options relating to the propertv's potential to generate income. He cites no relevant facts to support this argument nor does he cite any legal authority for the argument. C. Barbara Mumma Barbara Mumma first argues the sale of the UPS property should not be approved because Lisa Morgan did not provide the advance notice to her and to all the other the owners of the UPS property in accordance with the MRA I agreement. She provides no legal authority for this argument and does not attempt to distinguish Judge Sheeley's findings and determination in this matter at Docket No. 66 Equity 1988. Barbara Mumma's next argues that because Lisa Morgan failed to make distribution to the trust's assets to the Estate's residuary beneficiaries following, the death of her mother, as directed in her father's will, she has violated her duties of impartiality. She cites the PEF Code as her authority: "If a trust has two or more beneficiaries, the trustee shall act impartially in investing, managing and distributing the trust property, giving due regard to the beneficiaries' respective interests in light of the purpose of the trust. (20 Pa. C. S. Section 7773)." Barbara Mumma asserts that had Lisa Morgan followed her duties as set fbrth in the Will and the PEF Code and distributed the Estate's proportional share of the MRA I assets equally among and between the residuary beneficiaries, the Estate's ownership interest: would have been reduced to zero and each of the four beneficiaries' respective share of ownership would have been increased by 20.45626701%. This would result in Lisa Morgan in her capacity as trustee and individual not 18 having authority and control of a majority interest. She argues this failure to distribute is a ploy to maintain majority control and not grant first rights of refusal to the other owners. Barbara Mumma cites the Restatement (Third) of Trusts, Section 79 (2007) as authority for this position but offers no Pennsylvania legal authority accepting that section or any other legal authority supporting this argument. Barbara Mumma next argues that Lisa Morgan did not consider other options with respect to the UPS property that would be less detrimental to the Gibson property. She offers no factual or legal authority for this argument. Barbara Mumma also argues that Lisa Morgan has no right or authority to sell any other property and should transfer the assets equally share and share alike to the four residuary beneficiaries. She stated she adopted Robert M. Mumma's arguments in support of her position, but provided no additional legal authority in support of the same. AUDITOR'S RECOMMENDATION AND REASONING The parties have agreed to the facts of this matter through a stipulation and also other facts supplemented during their oral argument and facts of record. After reviewing not only their arguments and their authorities, the agreements, the Last Will and Testament of Robert M. Mumma and its Fist Codicil, the decisions of this honorable Court, the Pennsylvania Superior Court and the Pennsylvania Supreme Court, I would recommend that the sale of the UPS property should be approved. I would further recommend that Lisa Morgan, in her capacity as surviving trustee. has the authority over all the assets of the estate of her father and the trusts created thereunder, including the authority to develop and the discretion to implement a plan of 19 liquidation of those assets; and following that, to distribute the resulting assets in equal shares without the concurrence of the residuary beneficiaries and without further order of this Honorable Court. The MRA Agreements As determined by this Honorable Court many years ago. the NIR.A 1 and MRA II agreements were simply legal vehicles developed_ approved and executed by the Estate of Robert M. Mumma., his wife and his four children, after consultation with accountants and tax attorneys, to take advantage of certain benefits (i.e. The General Utilities Doctrine) of the then federal tax code which were set to expire on December 31. 1986. ("Tax Reform Act of 1986, effect January 1, 1987. citation omitted) (See Judge Sheely's Opinions and Orders at Docket 66 Equity 1988. supra.) These vehicles provided a great tax benefit to the estate and ultimately to the beneficiaries. These agreements specifically segregated and separated certain Estate assets which were not part of Robert M. Mumma's date of death quarrying operations. Their additional purpose was to insure the Estate's power to control those assets without interference from minority owners which were then Mrs. Mumma and her four children. These agreements were drafted and executed prior to any funding of the trusts established under Mr. Mumma"s Last Will and Testament. As Judge Sheely determined the minority- owners not only executed the agreements but also executed irrevocable powers of attorney and other documents in favor of the Estate. Judge Sheely did determine that the agreements and/or the assets represented by the agreements were duly transferred to the trustees. Judge Sheely also determined that during their administration of the Estates and the trusts created thereunder, the trustees. Barbara McK. 20 Mumma. the wiJow of Mr. Mumma, and Lisa Morgan held a super majority ownership, thus controlling interest. This controllino interest conferred upon them as trustees near absolute power over the assets. The trustees could treat them as their own and, irrespective of the notice requirements of the agreements, they, acting as the trustees, were not required to seek or obtain the prior permission or consent of the residuary beneficiaries: Robert M. Mumma, IL Barbara M. Mumma. Linda Mumma or Lisa Morgan, the children of Mr. Mumma. In the matter of the sale of the UPS property and the matter of future dispositions of property, the dispositive ownership interest of the trusts in the assets included in the MRA I and MRA II Agreements has not changed. Furthermore, the reasoning for the agreements has not changed therefore, there is no need to seek nor receive approval from any one or any combination the minority owners. INTERPRETATION OF THE LAST WILL AND TESTAMENT OF ROBERT M. MUMM.A AND THE TRUSTS CREATED THEREUNDER The Pennsylvania Superior in its opinion filed February 22, 2012 (see Mumma v. Estate of Mumma, 40 A.3d 198, 2411 (Pa. Super. Ct., 2011)), rejected Robert M. Mumma, II's argument that Lisa Morgan had the duty to distribute the trusts' assets to him and his siblings immediately following the death of their mother, Barbara McK. :Mumma. The Court also determined her failure to distribute immediately neither evidenced a conflict of interest nor grounds for her removal as trustee or personal representative. Robert M. Mumma, II had petitioned this Honorable Court requesting Lisa Morgan be removed as trustee and executrice of his father's Estate based an alleged conflict of interest. This Honorable Court determined he had not provided sufficient evidence to support his claims and denied his petition. The Superior Court addressed the issue raised by Robert M. Mumma II relating to Lisa Morgan's powers and 21 duties as trustee. - While listed as six distinct issues. Mumma 11 essentially presents a single I C issue for our consideration. namely whether Morgan*s roles in connection with the estates of :Mumma. Sr. and Mrs. Mumma constitute a conflict of interest requiring her disqualification and removal." Id. at 49. In addition to his contention that Lisa Morgan had failed to make required distributions to him and his siblings following the death of his mother, Robert M, Mumma. 11 also suggested that Lisa Morgan and the late Mrs. Mumma had improperly transferred assets from the 'Trusts established under his father's will to a separate independent trust in Florida controlled by his mother. The Superior Court affirmed this Honorable Court's finding of insufficient evidence to support any allegation of wrongdoing on the part of Lisa Mumma and continued: -With respect to the distribution of assets to the four sibling beneficiaries, the trial court determined that Morgan's testimony established she is completing the process of obtaining valuations of the estate and trust assets and has asked the beneficiaries if they have a preference regarding the receipt of any particular assets or cash and that she intends to make an equitable distribution of the assets to the beneficiaries after collecting the information. We agree with the trial court that this approach does not constitute any breach of fiduciary duty. Mumma, Sr. specifically provided Morgan, in her role as his personal representative when making an equal distribution among the four sibling beneficiaries, with the power to decide how to "make distribution of any trust herein created, either in money or in kind, or partly in money and partly in kind." Item Ninth (10), quoted supra. Mumma, Sr. further indicated that the "judgment of the trustees as to what shall constitute an equitable distribution or apportionment shall be binding and conclusive upon the beneficiaries hereof."" Id. at 50. (emphasis added) Robert M. Mumma 11 argues that the issue before the Superior Court differs from the issue involved in the matter before this Honorable Court and thus the statements relating to the duty to distribute or not to distribute trust assets is dicta. Robert M. Mumma, 11 was the party who raised this specific issue in his appeal to the Superior Court. It is ironic that he now argues the issue to which he demanded an answer should now not be controlling. 22 Black's Law Dictionary defines dicta, in pertinent part, as follows: "Expressions in court's opinion which go beyond the facts before court and therefore are individual views of author of opinion and not binding in subsequent cases." Black's Law Dictionary, 408 (5th ed. 1979). The portion of the opinion relating to Lisa Morgan's powers and duties under the Last: Will and Testamnet of Robert M. Mumma do not go beyond the facts and issues presented on appeal. It is not the individual view of the Judge, but an interpretation of the Last Will and Testament based on the current status of the law. Assuming, even for argument sake, that the statements and reasoning of the Superior Court is dicta, which it is not, the reasoning is still persuasive. As set forth below, Robert M. Mumma in his Last Will and Testament set forth specific and detailed duties and direction to his trustees and granted them broad discretionary powers. The death of Mrs. Mumma may have triggered some additional duties on the part of Lisa Morgan, as surviving trustee, but it did not require her to immediately transfer any assets to the four residuary beneficiaries of the Estate and the trusts created thereunder. The death of Barbara McK. Mumma, the life beneficiary of the trust, ended the primary purpose of the trust; however, there remained the duty and responsibility to distribute the assets equally among and between the residuary beneficiaries. Thus, as a result, the trust and the estate must continue until the distributions are completed and the estate closed. A reasonable interpretation of the Last Will and Testament of Robert M. Mumma, a review of applicable Pennsylvania case law, together with an interpretation of applicable provisions of the PEF Code lead the undersigned to this conclusion. "When interpreting the provisions of a trust, "the polestar in every trust is the settlor's intent and that intent must prevail. The rules for determining a settlor's intent are the same for a trust as for a will. The settlor's intent must be ascertained from a 23 consideration of(a) all the language contained in the four corners of the instrument and (b) the distribution scheme and (c) the circumstances surrounding the testator or settlor at the time the will was made or the trust was created and (d) "the existing facts." Technical rules or canons of construction should be employed only if the language of the instrument is ambiguous or conflicting or the intent of the settlor or testator is for any reason uncertain. When provisions of a trust instrument conflict, "they should be read in such a fashion as to give effect to both and/or fulfill the intent of the settlor." In Re Stella Scheidmantel , 2005 Pa. Super. 6; 868 A.2d 464, 488 (2005), citing In re Trust of Hirt, 2003 Pa. Super 287, 832 A.2d 438, 448 (2003) (other cites omitted). The Pennsylvania Supreme Court has also given direction on construction of wills and the proper method to interpret the intent of the testator: "The primary consideration in the construction and interpretation of wills is that the intent of the testator be followed . . . Absent ambiguity, that intent is to be determined from "the four corners of his will," . . . The duty of the court is not to determine what the testator might or should have said in light of subsequent events but, rather, the actual meaning of the words used . . . Only if the language employed by the testator is ambiguous should the court resort to canons of construction. (citations omitted) Estate of Blough, 474 Pa. 1771 185, 378 A.2d 276, 280 (1977). It is quite clear from the wording of Mr. Mumma's Last Will and Testament that the primary purpose for the trusts was to benefit his wife, Barbara McK. Mumma, during her lifetime. The Seventh section reads in part : "If my wife, BARBARA McK. MUMMA, survives me, I give and bequeath to the trustees hereinafter named, an amount equal to fifty (50%) percent of my total gross estate ... . I direct that the trustees hold said amount, In Trust Nevertheless, to manage, invest and reinvest the same, to collect the income and to pay over or apply the net income to, or for, the benefit of my wife, BARBARA McK. MUMMA." The Eighth Section provides in part: " All the rest, residue and remainder of my property and estate, I give, devise 24 and bequeath unto the trustees hereunder named ... to hold ... for the benefit of my wife, BARBARA McK. MUMMA.- Further evidence that the trust's purpose is also contained in the Seventh and Eighth Sections which both provide that upon the death of his wife. Barbara McK. Mumma, the principal of the trust ... shall be paid over by his surviving trustee or his successor Executor to his children: ROBERT M. MUMMA, I1, BARBARA M. McCLURE, LINDA M. ROTH and LISA M. MUMMA, free of this trust, share and share alike, per stripes and not per capita." The PEF Code supports the conclusion that the trust has terminated. It provides, in part "A trust terminates to the extent it ... expires pursuant to its terms, and no purpose of the trust remains to be achieved. " 20 Pa.C.S. § 7740 (2012). The terms of Mr. Mumma's Last Will and Testament clearly and specifically state when the trusts shall terminate. The Tenth Section, paragraph 18 of the will states: "As to each Trust created herein, to exercise all the powers granted and all the duties imposed herein until such time after the termination of that Trust as the property included in that Trust has been fully distributed and to do all other acts which, in their judgment, may be necessary or appropriate for the proper or advantageous management, investment or disposition of any property included in any Trust created herein." The final purpose of the trust: is also to insure that its assets are equally distributed to his four children and Lisa Morgan, as Mr. Mumma's trustee, has been designated by her late father to be the person to complete this final duty. One thing I have gleaned through the many days of hearing over these past years is the Late Mr. Mumma was a very savvy business man who loved his wife and children. He knew that his business interests were many, that he had vast assets and a great amount of debt. He knew the administration of his Estate would be a complex matter. Mr. Mumma established a very detailed 25 plan for the administration and distribution of his estate with the advice of several noted and respected estate attorneys and accountants. He knew and understood that which he desired and all provisions of his ten page Last Will and Testament and his three page First Codicil have meaning to insure his wife was protected and provided for during her lifetime, but who he desired to control and administer his Estate. Mr. Mumma had active business interests in differing fields and understood that the administration of his estate would not be performed in a vacuum. A close reading of the first codicil provides further insight to Mr. Mumma's intent that Lisa Morgan, as trustee, and she alone has been granted the authority to liquidate the trusts' assets. The first paragraph names his co-Executrices: his wife and daughter, Lisa Morgan. In the event that one or both of the named co-exeutrices are been unable to serve he appointed his daughter Barbara McClure, now Mumma, as his substitute co-executrix. However in the codicil continues: "I do now nominate, constitute and appoint my wife, Barbara McK. Mumma, and my daughter, Lisa M. Mumma, now Lisa M. Morgan, to be the co-Trustees of both trusts established by me ... In the event that my daughter Lisa M. Morgan should renounce this office, ... predecease me, or for any reason is unable to serve in the capacity as Trustee, then ... I direct that my daughter Barbara M. McClure, shall be the successor co-trustee to serve as co-Trustee with my wife ... Upon the failure for any reason of my daughter Barbara M. McClure to serve in that capacity, the Dauphin Deposit Bank and Trust Company, of Harrisburg, Pennsylvania, is constituted and appointed to serve as successor co-Trustee with my wife , in both trusts herein created." By this language Mr. Mumma intended and believed that as long as she lived, his wife would continue to be the trustee with either one of his two daughters or the bank's trust officer. If Lisa Morgan became incapable, Barbara McClure [now Mumma] would be her replacement. What must be noted is that Mr. Mumma did not name a successor trustee in the event of his 26 wife's inability to act or her death. It evidences his intent that the remainino, trustee should act alone. The language used in the two testamentary trust provisions further evidence Mr. Mumma's intent that Lisa Morgan is granted the authority to act alone in the method of distribution of the assets in equal shares to the beneficiaries. While the fifth paragraph of the Seventh Section provides "Upon the death of my said wife, the principal of this Trust, as it is then constituted, shall be paid over by my surviving Trustee unto my children, ROBERT M. MUMMA, 11, BARBARA M. McCLURE, LINDA M. ROTH and LISA M. MUMMA, free of this trust, share and share alike, per stripes and not per capita."' The second paragraph of the EIGHTH Section of Mr. Mumma's Last Will and Testament provides, in part " Upon the death of my wife, the principal of this trust, ... shall be paid over by my surviving trustee or by my successor executor, as the case may be, unto my children: ROBERT M. MUMMA, 11, BARBARA M. McCLURE, LINDA M. ROTH and LISA M. MUMMA, free of this trust, share and share alike, ..." Although the wording may differ between the trust provisions in the Eighth Section and the Seventh Section, the effect is the same, Lisa Morgan., as the surviving trustee, has the authority to liquidate and distribute those assets among and between the four named beneficiaries. The words "upon the death of my wife" show Mr. :Mumma's understanding that his wife could pass at any time following the establishment of his estate, and she did. There are two sets of circumstances to which the phrase which follows the words my surviving trustee or by my successor executor, "as the case may be" refer. They are: (I) if wife dies before the trusts are funded or (2) if wife dies after the trusts are funded. If the :facts in the former case had 27 occurred, no trusts would have been funded or established therefore there would be no surviving trustees, only executrices. However, the facts of the latter did occur and his wife. Mrs. Mumma, died after the funding, establishment and administration of the trusts. Therefore fie intended surviving trustee,. Lisa Morgan would act alone in distributing the residuary trust's assets in equal shares to the beneficiaries. Mr. Mumma's intent is controlling and the language used is evidence of that intent. When a personal representative is chosen by the testator himself, this appointment "represents an expression of trust and confidence in the person or persons so selected" by the testator. Beichner Estate, 432 Pa. 150, 155, 247 A.2d 779, 781 (1968). Mr. Mumma would riot have granted powers which would conflict and which would hinder the proper administration of his estate. (cites omitted) He did not intend an absurd result. (cites omitted). He specifically provided that the "judgment of the trustees as to what shall constitute an equitable distribution or apportionment shall be binding and conclusive upon the beneficiaries hereof""Mumma v. Mumma Estate, supra. at 50. (Emphasis added). The argument that Lisa Mumma is somehow violating the PEF Code's requirement that all beneficiaries be treated equally because she is exercising the powers and duties granted to her as trustee is wholly without merit. 28 The UPS Property Barbara Mumma has argued that Lisa Morgan may not have thoroughly investigated the impact such a sale of the UPS property would have on the Gibson property. She also questioned whether the Estate should reserve a right of way on the UPS property and how such a request might affect the transaction. The parties do have an ownership interest in the contiguous sixty-one (61) acres of the Gibson property. Robert A Mumma 11 and Barbara Mumma blindly argue and speculate as what may or may not have an effect on the Gibson property without actual evidence of the same or supportive legal authority. They both originally argued selling the UPS property would curtail access to UPS Drive and as a result, limit the Gibson property's access to that offered by Gibson Boulevard. During our first of many telephone conferences t reviewed both the aerial photos available on Microsoft's Google Earth website and the US Geological website and requested the parties to also review the same. By these photos it appeared that the Gibson property had access to both Ups Drive and Gibson Boulevard irrespective of that afford by the UPS property. Lisa Morgan's counsel later provided copy of aerial photography layered with the parcels as shown by the Dauphin County tax mapping section (now also available on their website) and the objectors revised their argument stating the access was several hundred feet past the access the offered by the UPS property. They argued this added distance and the fact UPS Drive's improved portion terminates at the Gibson property might somehow diminish the value the Gibson property. No evidence supporting this argument was offered and no continuance requested to produce such evidence. The basic argument was that Lisa Morgan may not have investigated alternative uses., alternative methods of transferring the property while reserving 29 certain property rights ( i.e. easements or lease backs, etc) and she had not consulted with the Objectors. She did not because she was not required to do so as she had the discretion to do so. Not only does Lisa Morgan have great discretion in selling the property, she negotiated a price which exceeds the appraised value by $145,000.00. Therefore. f recommend Your Honor approve the Petition to sell the UPS property. Liquidation and Distribution of Remaining Estate Assets Lisa Morgan has petitioned Your Honor to permit her to soleby, begin the process of distribution of the Estate's Assets to the residuary beneficiaries. For the reasons detailed above I would recommend, at this time, the petition be granted. Under the terms of Robert M. Mumma's Last Will and Testament Lisa.Morgan has the clear authority, to begin a plan of liquidation and to thereafter distribute the assets among and between the four children in equal shares of any and all the remaining assets in the trust established under the Seventh Section (the marital trust) and the Eighth Section (the residuary trust) of the Last Will and Testament of Robert M. Mumma. I further recommend that if your Honor agrees with my recommendations, you enter Orders accordingly and I have attached a two recommended orders to accomplish the same. Respectfully submitted, D.CB�uckle quire, *Jitor Supreme 0 Supreme Court 1D 38444 1237 Holly Pike Carlisle, PA 17013 (717) 249-2448 JoeBLaw=&,aolxom 30