Loading...
HomeMy WebLinkAbout10-27-14 RECORDED OF=ICE OF RE�`I,T;.r; rT ,''jLLS ?014 00T 27 Pn 12 20 CLE,'-, . 0 CU14BEf,Lf:°, 4 r+t David A. Mills, Esquire PA 37192 BLAKEY, YOST, BUPP &RAUSCH, LLP 17 East Market Street York, PA 17401 (717) 845-3674 Attorneys for Petitioner, Randy L. Cramer IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION IN RE: No. 21-08-0544 ESTATE OF JUNE K. OTTO Late of South Middleton Township, Deceased OBJECTIONS OF RANDY L. CRAMER TO FIRST AND FINAL ACCOUNT AND PROPOSED DISTRIBUTION OF EDWIN R. OTTO AND PATRICK K. MYERS, CO-EXECUTORS OF THE ESTATE OF JUNE K. OTTO,DECEASED AND NOW, this 13th day of October, 2014, comes the Petitioner, Randy L. Cramer, by counsel, David A. Mills, Esquire of Blakey, Yost, Bupp & Rausch, LLP, who files these Objections to the First and Final Account and Proposed Distribution of Edwin R. Otto and Patrick K. Myers, Co-Executors of the Estate of June K. Otto, deceased, as follows: 1. Objection to the "Receipts of Principal" in the aforesaid Account: a. The First and Final Account and Proposed Distribution of Edwin R. Otto and Patrick K. Myers, Co-Executors of the Estate of June K. Otto, deceased, states "Receipts of Principal" to include the real estate of the Decedent at 331 East Old York Road, Carlisle, 1 V- Pennsylvania as if, on the date of death of the Decedent on May 2, 2008 and on May 16, 2008, the date the Fiduciaries acquired said real estate, the real estate was two tracts of land upon the Fiduciaries' Acquisition, as follows: Value of Assets Fiduciary Real Estate: Listed in Inventory Acquisition (d/o/d value) Value 331 East Old York Road, Carlisle, Pennsylvania $900,000.00 $285,000.00 ($615,000.00 Seller Financing Pursuant to Recorded Mortgage) 331 East Old York Road, South—37 Acres $ 85,000.00 $ 85,000.00 Carlisle, Pennsylvania (Transfer Pending payment of Transfer Taxes, Subdivision Costs, Real Estate Taxes and Expenses) b. The real estate of the Decedent, June K. Otto, at 331 East Old York Road, Carlisle, Pennsylvania, on the Decedent's date of death was a sin le tract of land, not two separate tracts as stated in the aforesaid Account. C. Prior to her death, Decedent, June K. Otto, stated her agreement with Petitioner, Randy L. Cramer, to subdivide her property and entered into an Agreement of Sale, dated, April 28, 2007, with Petitioner, Randy L. Cramer, which Agreement states, in pertinent part, as follows: 1. The Property to be Sold. Otto agrees to sell to Cramer, and Cramer agrees to purchase from Otto, all the real property, with farm buildings thereupon, which Otto now owns on the south side of Route 174 in the County of Cumberland, Township of South Middleton, Commonwealth of PA, and which is currently part of the premises known as 331 Old East York Road, Carlisle, PA. This parcel of land it is to subdivided (sic) from the remainder of 331 Old East York Road, Carlisle, PA at a later date, and is comprised of approximately 35 acres, more or less (to be called"the Southern Tract"). See, Petitioner's Exhibit 1, attached to the Petition of Randy L. Cramer to Compel Co- Executors to File Account. 2 d. Prior to her death, the Decedent, June K. Otto, acknowledged her said Agreement with Petitioner, Randy L. Cramer, as having occurred already in the Last Will and Testament of June K. Otto, deceased, dated, May 11, 2007, in pertinent part, as follows: (b) All of the remainder of my real estate which I may own which is located in South Middleton Township, Cumberland County, Pennsylvania, and which lies South of the southern line of East Old York Road, known as Pennsylvania Route No. 174, and which contains approximately 35 acres, I direct shall be transferred to my faithful friend RANDY L.CRAMER, his heirs and assigns, of 170 Red Tank Road, Boiling Springs, PA 17007, agreeable to the Agreement of Sale into which I entered with him on April 28, 2007, in which Agreement I agreed to convey the same to him for a consideration of$1.00 which he paid to me upon the execution of the Agreement of Sale. This Agreement of Sale was entered into by me with Randy L. Cramer in appreciation of the many kindnesses and help which he has extended to me over a period of a number of years. See, Petitioner's Exhibit 3, attached to the Petition of Randy L. Cramer to Compel Co- Executors to File Account. e. Contrary to the aforesaid Account, none of the "Subdivision Costs, Real Estate Taxes" or "Expenses" is to be borne by the Petitioner, Randy L. Cramer, but only the "Transfer Taxes," as set forth in the aforesaid Agreement, in pertinent part, as follows: 5. Transfer Tax. Cramer will pay the entire cost of any transfer taxes due upon the transfer of the Southern Tract. See, Petitioner's Exhibit 1, attached to the Petition of Randy L. Cramer to Compel Co- Executors to File Account. £ Contrary to the aforesaid Account, none of the "ESTIMATED RECEIPTS RECEIVED FROM RANDY CRAMER To TRANSFER 37 ACRES" should include "2008-2015 County/Township and School Taxes" of"$19,554.44," as the Fiduciaries persisted in a course of conduct to deny legal title and possession to the Petitioner, Randy L. Cramer, after the date of 3 death of the Decedent on May 2, 2008, the acquisition of said real estate by the Fiduciaries on May 16, 2008, and the subdivision of the property by the Fiduciaries on December 21, 2012. g. Contrary to the aforesaid Account, none of the `ESTIMATED RECEIPTS RECEIVED FROM RANDY CRAMER TO TRANSFER 37 ACRES" should include "Subdivision Costs" of "$17,380.30" as the Fiduciaries alone agreed to these costs solely either "Costs of Administration" as stated in the Account and Inheritance Tax return, or more properly as debts of the Decedent who had agreed with Petitioner, Randy L. Cramer, to subdivide "approximately 35 acres, more or less (to be called `the Southern Tract')" from her property at 331 East Old York Road, Carlisle, Pennsylvania. h. Under penalties of perjury, the Fiduciaries of the Decedent's Estate signed the Pennsylvania Inheritance Tax Return, which took all of the aforesaid "2008-2015 County/Township and School Taxes" and "Subdivision Costs" paid by the Estate as deductions, which the Department of Revenue allowed, because Edwin R. Otto and Patrick K. Myers, Co- Executors of the Estate of June K. Otto, deceased, were legally obligated to pay them, as follows: § 9126. Deductions Generally The only deductions from the value of the property transferred shall be those set forth in this part. Except as otherwise provided in this article, they shall be deductible regardless of whether or not assets comprising the decedent's taxable estate are employed in the payment or discharge of the deductible items. When a tax is imposed upon a transfer described in subsection (c) of section 2107 and section 2108,1 the deductions shall be allowed to the transferee only to the extent that the transferee has actually paid the deductible items and either the transferee was legally obligated to pay the deductible items or the estate subject to administration by a personal representative is insufficient to pay the deductible items 72 Pa. Stat. Ann. § 9126 (Emphasis added.) 4 2. Objection to the omission of "Gains and Losses on Sales or other Dispositions" from the aforesaid Account: a. On March 19, 2013, Douglas H. Miller, Agent for Edwin R. Otto and Patrick K. Myers, Executors of the Estate of June K. Otto, deceased, sold real property located at 331 Old York Road, Lot 1 94.298, and at 323 Old York Road, Carlisle PA 17015 in South Middleton Township to Jonathan R. Rudolph and Ruth Ann Rudolph for $900,000.00 on an inventory value of$285,000.00. b. The Account states no disposition of "all the real property, with farm buildings thereupon, which Otto now owns on the south side of Route 174 in the County of Cumberland, Township of South Middleton, Commonwealth of PA, and which is currently part of the premises known as 331 Old East York Road, Carlisle, PA. This parcel of land it is to subdivided (sic) from the remainder of 331 Old East York Road, Carlisle, PA at a later date, and is comprised of approximately 35 acres, more or less (to be called "the Southern Tract")," which the Decedent sold to Petitioner, Randy L. Cramer, but did not transfer to him by Deed. 3. Objection to the"Distributions of Principal to Beneficiaries": a. The aforesaid Account states under the heading, Distributions to Beneficiaries, in pertinent part, as follows: Distributions to Beneficiaries: 331 East Old York Road, South—37 Acres—Subject to Payment of Transfer Taxes, Subdivision Costs, Real Estate Taxes and Expenses.....................$85,000.00 b. No Beneficiary is named as to this Distribution. C. No Distribution of 37 acres at 331 East old York Road, Carlisle, Pennsylvania has been made. 5 d. No payment of "Subdivision Costs, Real Estate Taxes and Expenses" is supported in either the Agreement of Sale, dated, April 28, 2007, see, Petitioner's Exhibit 1, attached to the Petition of Randy L. Cramer to Compel Co-Executors to File Account, or the Last Will and Testament of June K. Otto, deceased, dated, May 11, 2007, see, Petitioner's Exhibit 3, attached to the Petition of Randy L. Cramer to Compel Co-Executors to File Account. Wherefore, Petitioner, Randy L. Cramer, respectfully requests this Honorable Court to sustain the Objections and enter an Order that directs Respondents, Edwin R. Otto and Patrick K. Myers, Executors of the Estate of June K. Otto, deceased, to transfer to him by Executor's Deed "all the real property, with farm buildings thereupon, which Otto [then] own[ed] on the south side of Route 174 in the County of Cumberland, Township of South Middleton, Commonwealth of PA, and which [was] part of the premises known as 331 Old East York Road, Carlisle, PA .... [and was] subdivided from the remainder of 331 Old East York Road, Carlisle, PA at a later date, and is comprised of approximately 35 acres, more or less." 4. Objection to the omission of "Receipts of Income" from the aforesaid Account: a. The First and Final Account and Proposed Distribution of Edwin R. Otto and Patrick K. Myers, Co-Executors of the Estate of June K. Otto, deceased, states no Receipts of Income during more than six (6) years of administration of the decedent's estate when it is believed, and therefore averred that the real estate of the Decedent at 331 East Old York Road, Carlisle, Pennsylvania has been leased to a farmer since the date of death of the Decedent on May 2, 2008 and the acquisition of said real estate by the Fiduciaries on May 16, 2008. 6 b. The First and Final Account and Proposed Distribution of Edwin R. Otto and Patrick K. Myers, Co-Executors of the Estate of June K. Otto, deceased, states under the heading,RECEIPTS OFPRINCIPAL,as follows: RECEIPTS OF PRINCIPAL Value of Assets Fiduciary Listed in Inventory Acquisition (d/o/d value) Value Personal Property: Stamy—Farm Rent Income $52,761.00 $52,761.00 RECEIPTS SUBSEQUENT TO INVENTORY (Value When received) 04/22/14 Jonathon R. Rudolph, Farm Rent Income...................... $2,000.00 If this income were other than due on Decedent's date of Death, then it is not truly a "Receipt of Principal." If Income in Respect of Decedent, there is no account of the income tax paid to the U.S. Treasury or to the Commonwealth of Pennsylvania. C. As Specific Devisee, Petitioner, Randy L. Cramer, is entitled to the net income from property given to him accrued from the death of the Decedent. See, Act of 1972, June 30, P.L. 508, No. 164, § 2, eff. July 1, 1972, as amended, 20 Pa.C.S.A. §3543 (b) (Income on Distributive Shares). d. As Specific Devisee, rental payments from business real estate belong to Petitioner, Randy L. Cramer, not the Estate. In re Estate of Sell (K.), 10 Fid. Rep. 2d 202, 49 Somerset, 26, aff'd 392 Pa. Super. 658, 564 A.2d 266, appeal denied, 525 Pa. 585, 575 A.2d 115 (1990). 7 Wherefore, Petitioner, Randy L. Cramer, respectfully requests this Honorable Court to sustain the Objections and enter an Order that directs Respondents, Edwin R. Otto and Patrick K. Myers, Executors of the Estate of June K. Otto, deceased, to account for Receipts of Income, if any, that are attributed to the real property, with farm buildings thereupon, which Otto [then] own[ed] on the south side of Route 174 in the County of Cumberland, Township of South Middleton, Commonwealth of PA, and which [was] part of the premises known as 331 Old East York Road, Carlisle, PA .... [and was] subdivided from the remainder of 331 Old East York Road, Carlisle, PA at a later date, and is comprised of approximately 35 acres, more or less. 5. Objection to the "Proposed Distribution" in the aforesaid Account: a. If the portion of the First and Final Account and Proposed Distribution of Edwin R. Otto and Patrick K. Myers, Co-Executors of the Estate of June K. Otto, deceased, which identifies the Proposed Distribution is the "FINAL DISTRIBUTION," it does not contain the name of Petitioner, Randy L. Cramer, to whom it is proposed to award the balance of the real estate of the Decedent at 331 East Old York Road, Carlisle, Pennsylvania for distribution, the amount of the share to be awarded to him, or a brief statement of the nature and reasons for the proposed award, be it a reference to the applicable provisions of the Will or Agreement, authorizing the proposed distribution. b. That portion of the First and Final Account and Proposed Distribution of Edwin R. Otto and Patrick K. Myers, Co-Executors of the Estate of June K. Otto, deceased, which identifies the Proposed Distribution is stated "FINAL DISTRIBUTION," but does not distribute to Randy L. Cramer the amounts set forth in"Reserves" as follows: 8 Reserves Randy L. Cramer, Lawn Care........................... $9,701.00 Randy L. Cramer, Property Clean Up..................... $1,640.00 TOTAL...................................................... $11,341.00 C. That portion of the First and Final Account and Proposed Distribution of Edwin R. Otto and Patrick K. Myers, Co-Executors of the Estate of June K. Otto, deceased, which identifies the Proposed Distribution is stated "FINAL DISTRIBUTION," but does not distribute to Jason L. Cramer the amounts set forth in the inheritance Tax Return, as follows: SCHEDULE H 12. Jason Cramer— Service Calls ........................ $725.00 13. Jason Cramer—HVAC repairs....................... $950.00 TOTAL........................................................... $1,675.00 Wherefore, Petitioner, Randy L. Cramer, respectfully requests this Honorable Court to sustain the Objections and enter an Order that 1. Directs Respondents, Edwin R. Otto and Patrick K. Myers, Executors of the Estate of June K. Otto, deceased, to transfer to him by Executor's Deed "all the real property, with farm buildings thereupon, which Otto [then] own[ed] on the south side of Route 174 in the County of Cumberland, Township of South Middleton, Commonwealth of PA, and which [was] part of the premises known as 331 Old East York Road, Carlisle, PA .... [and was] subdivided from the remainder of 331 Old East York Road, Carlisle, PA at a later date, and is comprised of approximately 35 acres, more or less 2. Pays $11,341.00 to Petitioner, Randy L. Cramer, and$1,675 to Jason Cramer. 9 6. Objection to the Affidavits of the Co-Executors to the aforesaid Account: a. The affidavit of Edwin R. Otto, Co-Executor states: Edwin R. Otto, Co-Executor for the Estate of June K. Otto, deceased, hereby declares under oath [under penalty of perjury] that he has faithfully discharged the duties of his office; that the foregoing First and Final Account is true and correct and fully discloses all significant transactions occurring during the accounting period; that all known claims against the estate have been paid in full; that, to his knowledge, there are no claims now outstanding against the Estate; and that all taxes presently due from the estate have been paid. /s/ Edwin R. Otto, Co-Executor b. The affidavit of Patrick K. Myers, Co-Executor states: Patrick K. Myers, Co-Executor for the Estate of June K. Otto, deceased, hereby declares under oath [under penalty of perjury] that he has faithfully discharged the duties of his office; that the foregoing First and Final Account is true and correct and fully discloses all significant transactions occurring during the accounting period; that all known claims against the estate have been paid in full; that, to his knowledge, there are no claims now outstanding against the Estate; and that all taxes presently due from the estate have been paid. /s/ Patrick K. Myers, Co-Executor C. The claims of Petitioner, Randy L. Cramer, for approximately 35 acres, i.e., "the Southern Tract" from the property of the Decedent at 331 East Old York Road, Carlisle, Pennsylvania, and for Lawn Care and Clean Up, as aforesaid, have not been satisfied. d. The claims of Jason Cramer for Service Calls and HVAC repairs are also now outstanding against the Estate. 10 WHEREFORE, Petitioner, Randy L. Cramer, requests this Honorable Court to sustain the Objections of Petitioner, Randy L. Cramer, and enter an Order that does the following: 1. Distributes the "approximately 35 acres, more or less (`the Southern Tract')" from the property at 331 East Old York Road, Carlisle, Pennsylvania, by deed from Edwin R. Otto and Patrick K. Myers, Co-Executors of the Estate of June K. Otto, deceased to Randy L. Cramer, who will record said Deed and pay Pennsylvania Realty Transfer Taxes attendant to recording the Deed in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania; 2. States the gains or losses on sales or other dispositions of all property of the Decedent; 3. Accounts for the Receipts of Income, if any, during the administration of the Estate of June K. Otto, deceased; 4. Pays to Petitioner, Randy L. Cramer, the sum of $11,341.00 for the Lawn Care and Property Clean Up; 5. Pays Jason Cramer the sum of$1,675 for Service Calls and HVAC Repairs. Respectfully, BL OST, BUPP . RAUSCH, LLP Dated: ���� 02o r'� B Davi A. Mills, Esq re PA 37192 ast Market Street York, Pennsylvania 17401 (717) 845-3674 Attorneys for Petitioner, Randy L. Cramer 11 CERTIFICATE OF SERVICE I, David A. Mills, Esquire, hereby certify that I have served a true and correct copy of the foregoing Objections of Randy L. Cramer to First and Final Account and Proposed Distribution of Edwin R. Otto and Patrick K. Myers,'Co-Executors of the Estate of June K. Otto, Deceased, by depositing a copy of same in the United States Mail, regular delivery, postage prepaid as follows: Douglas Miller, Esquire Irwin& McKnight, P.C. 60 West Pomfret Street Carlisle, PA 17013 BLAKEY,YOST, BUP & BAUSCH, LLP Dated:"PJ 6David . M ls, Esquire 37192 st Market Street York, PA 17401 (717) 845-3674 Attorney for Petitioner, Randy L. Cramer