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Home My WebLink About06-26-15 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RL: . ORPHANS COURT DNISION ESTATE OF ROBERT A. BROWN, : DECEASED : NO. 21 13-1172 ANSWER TO INHERITANCE TAX APPEAL TO THE HONORABLE JUDGES OF SAID COURT: AND NOW, this 24'h day of June, 2015, comes the Commonwealth of Pennsylvania, Department of Revwue, through its Office of Chief Counsel and by its Senior Counsel, Lora A. Kulick, and respectfully responds m this Petition as follows: 1. Paragraph one is admitted. 2. Paragraph two is admitted � 3. Paragraph three is admitted. 4. Paragraph four is admitted �� _ ' r� - o " i:� o 5. Pazagraph five is admitted '- '"' - - n �. . '�:� 6. Paragraph six is admitted. . � �. �� .. '. �-, z, 7. Paragraph seven is admitted � � -3 - '. �, �-' m 8. Paragraph eight is admitted. _ � � ^�� -� T w 9. Parap'aph nine is admitted. l0. Para�'aph ten is admitted. lJ 1 I. Paragraph eleven is denied. AppellanPs Disclaimer is a written document which speaks for itself. Any and all characterizations thereof specifically are denied. Further, the Department is wi[hout knowledge or information su�cient to form a belief as to what Appellant intended to disclaim. Specific proof is demanded. 12. Paragraph twelve is denied. AppellanPs Disclaimer is a written doeument which speaks for itself Any and all characterizations thereof specifically are denied. Fur[her, the Department is without knowledge or information sufficient to form a belief as to what Appellant intended to diselaim. Specific proof is demanded. 13. Paragraph thirteen contains a conclusion of law to which no responsive pleading is required. The same therefore is denied. 14. Pazagraph fourteen is denied. The Departmen[ is without knowledge or information sufficient to form a belief as to what Appellant endeavored. Specific proof is demanded. I5. Paragraph fifteen is admitted. 16. Para{,�aph sixteen is admitted. 17. Paragraph seventeen is admitted. 18. Paragraph eighteen is admittad. l9. Paragraph nineteen is admitted. 20. Paragraph[wenTy is admitted. 21. Paragraph twenty one is admitted. 22. Paragraph twenTy two is admitted. 23. Pazagraph twenty three is admitted. 24. Paragraph twcnty four is admit[ed. 25. Paragraph [wenty five is admi[ted. 26. Paragraph twenty six is admitted. 27. Paragraph twenty seven is admitted. 28. Paragraph twenTy eight contai�s a conclusion of law to which no responsive pleading is required. The same is therefore denied. 29. Paragraph twenty nine contains a conclusion of law to which no responsive pleading is required. The same therefore is denied. 30. Paragraph thirty is admitted. 31. Paragraph thiRy onc contains a conclusion of law to which no responsive pleading is required. The same is therefore denied. 32. Paragraph thirty two contains a conclusion of law to which no responsive pleading is required. The same is therefore denied. 33. Paragraph thirty three contains a conclusion of law to which no responsive pleading is required. The same is thcrefore denied. 34. Paragraph thirty four is denied. DecedenYs Will is a written document which speaks for itself. Any and all chazacterizations thereof specifically are denied. Further, the Department is without knowledge or information su�cient to form a belief as ro Decedent's intentions. Specific proof is demanded. 35. Pazagraph thirty five contains a wnclusion of law to which no responsive pleading is required. The same is therefore denied. 36. Para�'aph thirty six contains a conclusion of law to which no responsive pleading is required. The same is therefore denied. 37. Paza�aph thirty seven contains a statement of law to which no responsive pleading is required. The same is therefore denied. 38. Paragraph thirty eight contains a statement of law to which no responsive pleading is required. The same is therefore denied. 39. Pazagraph thirty nine is denied. The Department is without knowledge or information sufficient to form a bclief as to what Appellant expressed as her intentioa Spccific proof is demanded. 40. Paragraph foRy contains a conclusion of law to which no responsive pleading is required. The same is therefore denied. 41. Paragaph forty one contains a conclusion of law to which no responsive pleading is required. The same is therefore denied. 42. Paragraph forty two contains a conclusion of law to which no responsive plcading is required. The same is the�efore denied. WHEREFORE, the Commonwealth of Pennsylvania, Department of Revenue respectfully requests that this Cour[ deny Ihe Appeal and sustain in its entirety the Decision and Order of the Board of Appeals. Respectfully submitted by, O Lora A. Kulick Attomey for Respondent PA Department of Revenue O%ce of Chief Counsel P.O. Box 281061 Harrisburg, PA 17128-1061 Attomey I.D. No. 69436 COMMONWEALTH OF PENNSYLVANIA . ss COUNTY OFCUMBERLAND . The undersigned, beingduly swom accoiding[o law, deposes and sa}s that she is the�ief of the Inheritance Tax Division ofthe Bu�eau of Individual Taxes for the Commonwealth of Pennsylvania, Department of Revenue, that she is authorized to make this affidavit on its behalf, and that the ave�nents of the foregoing aze true and correct to the best of her knowledge, infortna[ion and belief. , . � � (/Z�' _ Suzac L. Tadini Swom to and S7ibscribed before me thisaydayof SunC-Z�15 ��A ( [ , a �, 1LIl � Dln —F�i� Notary Public My Commission Espires: �,,�� a5, �C;1lD ""ri�� c�nr �� .zois w�� r r?HUO�►Y�� : ,_�� Ii1/W.V� r1�YMM7�M IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENIVSYLVANIA IN RE: . ORPHANS' COURT DIVISION ESTATE OF ROBERT A. BROWN, : DECEASED : NO. 2113-1172 CERTIFICATE OF SERVICE I hereby certify that I am this 24°i day of June, 2015, serving a copy of the forcgoing document upon the person and in the manner indicated below, which service satisfies the requirements of Pa. Oryhans' Court Rule 5: SERVICE BY FIRST CLASS MAIL ADDRESSED AS FOLLOWS: Ivo V. Otto, III, Esq. Martson Law Offices 10 East High Street Carlisle, PA 17013 � o' Lqr A. C c Attomey for Respondent PA Department of Revenue Office of Chief Counsel P.O. Box 281061 Harrisbarg, PA 17128-1061 Attorney I.D. No. 69436 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: . ORPHANS' COURT DNISION ESTATE OF ROBERT A. BROWN, : DECEASED : NO. 2113-1172 PRAECIPE FOR APPEARANCE To Lisa M. Grayson, Esq., Clerk of Orphans' Court: Please enter my appearance for the Commonwealth of Pennsylvania, Department of Revenue, Respondent in the above-captioned matter. Datc: June24, 2015 � Lora A. ick Attomey for Respondent PA Department of Revenue Office of Chief Counsel P.O. Box 281061 Harrisburg, PA 17128-1061 Attomey I.D. No. 69436 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN RE: . ORPHANS' COURT DIVISION ESTATE OF ROBERT A. BROWN, : DECEASED : NO. 2113-1172 CERTIFICATE OF SERVICE 1 hereby ccrtify that 1 am this 24°i day of June, 2015, serving a copy of the foregoing document upon the person and in the manner indicated below, which service satisfies the requirements of Pa. Orphans' CouR Rule 5: SERVICE BY FIRST CLASS MAIL ADDRESSED AS FOLLOWS: Ivo V. Otto, III, Esq. Martson Law Offices 10 East High Street Cazlisle, PA 17013 Lora A. Ku ic� Atromey for Respondent PA Department of Revenue Office of Chief Counsel P.O. Box 281061 Harrisburg, PA 17128-1061 Attomey I.D. No. 69436