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HomeMy WebLinkAbout08-26-02IN THE COURT OF COMMON PLEAS. CUMBERLAND COUNTY, PENNSYLVANIA IN RE: ESTATE OF LOY T. HEMPT, Deceased ORPHANS' COURT DIVISION NO. Q.31 OBJECTIONS TO FIRST. AND FINAL ACCOUNT FOR THE ESTATE OF LOY T. HEMPT AND RESIDUARY TRUST UNDER WILL OF LOY T. HEMPT AND NOW, come Petitioners, W. Robert Mark, Forrest H. Mark, and Steven E. Mark, by and through their attorneys, ZULLINGER-DAVIS, P.C., and hereby file this objection to the First and Final Account of the Estate of Loy T. Hempt and Residuary Trust under Will of Loy T. Hempt. THE OBJECTIONS SET FORTH HEREIN ARE BASED ON THE FOLLOWING FACTUAL CONTEXT, WHICH PETITIONERS BELIEVE TO BE TRUE AND CORRECT: Loy T. Hempt died on March 19, 1977, a resident of Cumberland County, Pennsylvania. He left a will dated August 8, 1964, and a codicil dated December 12, 1969, which are both probated in the office of the Register of Wills of Cumberland County, Pennsylvania, hereinafter both the will and codicil are referred to as "the Loy T. Hempt Will." The Loy T. Hempt Will creates a residuary trust (hereinafter the "Residuary Trust") with the life interest currently represented by Jean Hempt. The remainder interest is currently represented as follows: forty (40%) percent thereof to the issue of Max Hempt, as he is deceased; the issue who share equally in the aforementioned forty (40%) percent are George F. Hempt, Marion H. Sendoff, Martha D. Bair, and Gerald L. Hempt; forty (40%) percent thereof to the issue of Dorothy Hempt Mark as she is deceased; her three issue (the petitioners herein), share equally her forty (40%) percent interest. Twenty (20%) percent to Robert Kalbach who is now living and if he is deceased at the time for distribution of the trust to his issue who are Robert Kalbach, Jr., and Richard C. Kalbach. The petitioners are nephews of Jean Doris Hempt, the life tenant under the aforementioned residuary trust. Jean Doris Hempt (hereinafter "Jean"), was born January 24,1927, in Cumberland County, Pennsylvania, and due to her mental retardation has resided for many years at the Woods School and Residential Treatment Center at Langhorne, Pennsylvania. She is unmarried, has no children and both of her parents are deceased. Jean had a brother and sister, namely Max C. Hempt who died in 1999, and Dorothy H. Mark who died in 1995. She was adjudicated to be an incapacitated person by final decree of this Honorable Court dated March 8, 1985. Further, in a final decree dated May 10,1990, this Honorable Court named Max C. Hempt and Dorothy H. Mark guardians of the person of Jean. Jean's intestate heirs consist of the issue of Max Hempt, namely George F. Hempt, Gerald L. Hempt, Marion H. Sendoff, and Martha D. Bair, and the issue of Dorothy Hempt Mark, namely W. Robert Mark, Forrest H. Mark and Steven E. Mark. The will of Loy T. Hempt names Max C. Hempt and Margaret Hempt, the widow of Loy T. Hempt as trustees of the Residuary Trust for the benefit of Jean and provides that Dorothy H. Mark be an alternate residuary trustee. Margaret Hempt died on September 4,1988, and thereafter Dorothy H. Mark died on June 15, 1995. These deaths 2 created a vacancy in the fiduciary positions of co -trustee with Max C. Hempt for the Residuary Trust for Jean's benefit under the will of Loy T. Hempt and as co -guardian of the estate and person of Jean. On June 3, 1996, Max Hempt and Gerald L. Hempt filed a petition with this Honorable Court captioned "In the Matter of Jean Doris Hempt, an Incompetent" (Exhibit "A" attached hereto). The petition requested that Gerald L. Hempt be appointed as a successor trustee with Max Hempt under the Residuary Trust created by the Loy T. Hempt will, as well as the trust under the will of Jean's father, George Hempt, and as co - guardian of the estate and person of Jean. The Court on September 3,1996, entered an order granting the petition of Max C. Hempt and Gerald L. Hempt (Exhibit B attached hereto). Max C. Hempt died on May 23, 1999, and Gerald L. Hempt has acted as sole trustee under the Residuary Trust created by the will of Loy T. Hempt and as sole guardian of the estate and person of Jean. However, no proceedings have been instituted to have a successor personal representative appointed for the estate of Loy T. Hempt. By his filing this account, Gerald L. Hempt apparently has assumed that position in spite of there being no appointment by the Register of Wills of Cumberland County. At the time of his death, Loy T. Hempt, owned shares in the common stock of C.A. Hempt Estate, Inc., a Pennsylvania corporation, whose principal business is dealing in commercial real estate in Cumberland County, Pennsylvania. Loy T. Hempt also owned shares in Valley Land Company, which your petitioners assume is a company owning real estate. Further, Loy T. Hempt held shares of stock in Hempt Brothers, Inc. All three of these holdings are listed in the account filed by Gerald L. Hempt. Gerald L. stocks were not distributed to Robert Kalbach because of his business competition with Hempt Brothers, Inc. However, the decedent, Loy T. Hempt, was aware of such conflicting interests prior to his death and yet he chose to distribute his Residuary Trust on a pro-rata fractional basis following Jean's death. 2. 20 PA. C.S.A., Section 7191, subsection (a), as amended by Act 39 of 1999, P.L. 422, was adopted to aid in the qualification of trusts as qualified shareholders for subchapter S purposes, as well as for Generation Skipping tax purposes. The intent of the legislature was not to permit a trustee to gain personal advantage or control the interests in closely held corporations to the detriment of other beneficiaries. 3. The amendments to 20 PA. C.S.A. Section 7191 in 1992 and 1999, were specifically not made to apply retroactively to a trust under a will executed in 1964 by a decedent who died in 1977. In fact, Section 7191 at the time of the death of Loy T. Hempt, provided only that the court "for cause shown and with the consent of all parties in interest may divide a trust into two or more separate trusts". 4. If 20 PA. C.S.A. Section 7191(a), as amended, is deemed to apply in this matter, it would be a violation of both the Pennsylvania and United States Constitutional protections afforded petitioners against an illegal taking of property. 5. The attempt by the accountant, who, in his individual capacity, is a substantial owner in various businesses in which the Residuary Trust holds stock and a remainder beneficiary under the Residuary Trust, to divide the assets of the Residuary Trust into three separate trusts is on its face a conflict of interest. 6. The petitioners, despite the fact that they own stock in C.A. Hempt Estate, Inc. and despite the fact that they have attended various board meetings of this entity over the years, do not have sufficient information to determine the fair market value of C.A. Hempt Estate, Inc. Accordingly, the petitioners cannot determine whether the distributions proposed by the accountant are fair to all parties in interest, which is their primary concern. The same is true of Hempt Brothers, Inc. This is true despite the fact that petitioners may in fact benefit significantly on a financial basis from the proposal as set forth by the accountant. 7. The petitioners do not object to the distribution of assets from the Loy T. Hempt Residuary Trust on a pro rata fractional share basis for each asset. B. Even if, the accountant is deemed to have the authority to divide the assets of the Loy T. Hempt Residuary Trust into three separate trusts on a non -pro -rata fractional basis, the petitioners object to the valuations presented by the accountant, especially in light of the fact that neither the petitioners nor the 6 court have sufficient information concerning the valuation of Hempt Brothers, Inc., Valley Land Company, and C.A. Hempt Estate, Inc. 1. The valuation report prepared by C.A. Hempt Estate, Inc. for a shareholders' meeting reflects the December 31, 2000 value of the corporation at $211.44 per share (Exhibit C herein). The Loy T. Hempt Residuary Trust holds 6,000 shares which, based on the corporation's own valuation at the end of the year 2000, would make a fair market value of $1,268,640.00. The accountant used the value of $104.00 per share. There is no reference in the account as to why the valuation of the shares plummeted. The petitioners and the court have a right to know how the valuation of the stock in the C.A. Hempt Estate, Inc. was arrived at. If the accountant used some type of discounted valuation, the petitioners object to the impact of a discount benefiting some beneficiaries and not others. 2. The valuation of Hempt Brothers, Inc. appears low and does not reflect its fair market value. In 1975, the petitioners' mother, Dorothy Hempt Mark, sold her shares in the company for $653.00 per share. The accountant used a per share valuation in his account considerably less than that. The account does not reveal a method of valuation to allow the petitioners or the court to make an independent judgment of the fairness of the valuation. Petitioners do not have, nor have they ever seen a copy of the alleged buy -sell agreement covering Hempt Brothers, Inc. 3. The valuation of Valley Land Company does not properly reflect its fair market value in that the accountant's use of the common level ratio to determine the value of Valley Land Company stock is incorrect and inappropriate. The common level ratio is a statutory creation which was not intended to determine fair market value. 4. All of the petitioners' concerns about valuation could be resolved by a prorated fractional distribution into three separate trusts of each asset in the Loy T. Hempt Residuary Trust. C. In addition to the above, the Petitioners object to various actions on the part of the accountant, which appear to be a breach of the accountant's fiduciary duty to all of the beneficiaries. 1. The accountant was never appointed executor of the Loy T. Hempt Estate by the Register of Wills of Cumberland County following his father's death. 2. The accountant distributed in December of 2000, principal assets to Jean's estate which were later reimbursed to the Loy T. Hempt Estate and Residuary Trust. The reimbursement did not include compensation for lost income from the funds before they were reimbursed in January of 2002. 3. In selling assets of the Loy T. Hempt Estate and Residuary Trust to make a distribution of principal to Jean's estate, a fiduciary income tax obligation would be triggered on any capital gain, thus incurring 8 objections or, in the alternative; that the Court consider the same and that the auditor or Court consider the following relief: 1 Declare the distribution of the Loy T. Hempt Residuary Trust into three separate trusts to be null and void. 2. In the alternative, if the Loy T. Hempt Residuary Trust is to be divided into three separate trusts, order the allocation on a pro rata basis based on the fractional shares set forth in the Loy T. Hempt will for each asset. 3. Order an independent corporate fiduciary to serve with Gerald L. Hempt or alone as Administrator d.b.n. c.t.a. for the Estate of Loy T. Hempt and as trustee of all trusts created under the will of Loy T. Hempt. 4. Order the accountant to reimburse the Loy T. Hempt Estate and Residuary Trust in an amount equal to tax penalties, interest incurred and loss of the use of funds suffered by the estate and trust due to the $200,000.00 principal distribution to Jean's estate. 5. Order the accountant to reimburse the trust in the amount of $44,818.20 representing the amount of expenses improperly paid for the benefit of Valley Land Company. 6. Order the accountant to reimburse the Residuary Trust for legal fees paid or incurred since January 2001 from the assets of the Residuary Trust. 7. Order the accountant to reimburse the petitioners for their legal fees or expenditures in connection with the accountant's management of the Estate of Loy T. Hempt and the Residuary Trust. 10 8. Grant such other relief as the Court, in its judgment, deems necessary and appropriate. 11 Respectfully submitted, ZULLINGER-DAVIS, P.C. By r. oel R. Zullinge Sup. Ct. I.D. N. 7516 14 North Main Street, Suite 200 Chambersburg, PA 17201 (717)264-6029 Attorney for Petitioners CERTIFICATE OF SERVICE AND NOW, this c,,26 'day of August, 2002, I certify that I am this day serving a copy of the foregoing document upon the persons and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of same in the United States Mail, Chambersburg, PA, with first class postage prepaid, as follows: Jerry R. Duffle, Esquire David W. DeLuce, Esquire 301 Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Attorneys for George F. Hempt And Gerald L. Hempt Daniel L. Sullivan, Esquire 3401 N. Front Street, P.O. Box 5950 Harrisburg, PA 17110-0950 Attorney for Robert Hempt Kalbach, Sr., Robert H. Kalbach, Jr. and Richard C. Kalbach Gerald L. Hempt P.O. Box 278 Camp Hill, PA 17001-0278 Robert H. Kalbach, Sr. 1 W. Lawn Circle Wormleysburg, PA 17043 Richard C. Kalbach 3 Manassas Court Mechanicsburg, PA 17055 12 Marion K. Semoff 410 Candlewyck Road Camp Hill, PA 17011 Martha D. Blair 225 North Ridge Road Perrysburg, OH 43555 George F. Hempt 763 Limekiln Road New Cumberland, PA 17070 Jean Doris Hempt c/o Gerald L. Hempt Guardian of Estate and Person of Jean Doris Hempt P.O. Box 278 Camp Hill, PA 17001-0278 Robert H. Kalbach, Jr. 6339 Creek View Road Mechanicsburg, PA 17055 Richard W. Stevenson, Esquire McNees, Wallace & Nurrick, LLC Pine Street, P.O. Box 1166 Harrisburg, PA 17108 VERIFICATION I, Steven E. Mark, have read the foregoing document and verify that the facts set forth herein are true and correct to the best of my knowledge, information and belief. To the extent that the foregoing document and/or its language is that of counsel, I have relied upon counsel in making this verification. I understand that any false statements made herein are subject to the penalties of 18 Pa. C.S.A., Section 4204 relating to unsworn falsification to authorities. Steven E. Mark VERIFICATION I, W. Robert Mark, have read the foregoing document and verify that the facts set forth herein are true and correct to the best of my knowledge, information and belief. To the extent that the foregoing document and/or its language is that of counsel, I have relied upon counsel in making this verification. I understand that any false statements made herein are subject to the penalties of lP C.S.A., Section 4204 relating to unsworn falsificatio r • autho 4irg; J DATED: W. Robert Mark VERIFICATION I, Forrest H. Mark, have read the foregoing document and verify that the facts set forth herein are true and correct to the best of my knowledge, information and belief. To the extent that the foregoing document and/or its language is that of counsel, I have relied upon counsel in making this verification. I understand that any false statements made herein are subject to the penalties of '18 Pa. C.S.A., Section 4204 relating to unswom falsification to authorities. DATED: ahyoa., Forrest H. Mark IN THE MATTER OF JEAN DORIS HEMPT, AN INCOMPETENT COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION Nos. 2008 of 1942, 253 of 1977, and 117 of 1985 PETITION FOR APPOINTMENT of SUCCESSOR TRUSTEE and SUCCESSOR GUARDIAN OF ESTATE and of PERSON The Petition of Max C. Hempt and Gerald L. Hempt respectfully represents: 1. Petitioner Max C. Hempt is the brother of, and Petitioner Gerald L. Hempt is the nephew of, Jean Doris Hempt (hereinafter "Jean") whose domicile is Cumberland County, Pennsylvania. 2. Jean was born on January 24, 1927 in Cumberland County, Pennsylvania, and because of a disability, has since 1937 been a resident at The Woods Schools and Residential Treatment Center, Langhorne, Pennsylvania, a privately owned institution. 3. Jean is unmarried and has no children. Her parents are deceased. 4. Jean has two siblings - namely, a sister, Dorothy H. Mark, who died June 15, 1995, and the Petitioner, Max C. Hempt. 1 Exhibit A 5. Jean, because of mental retardation, is unable to manage her property or her. person, is liable to become the victim of designing persons, and lacks sufficient capacity to make and communicate responsible decisions concerning her property or person. Attached hereto and incorporated herein by reference as Exhibit "A", is an affidavit, dated January 28,. 1985, of Jean's physician at the time, Stanley Gould, M.D., which sets forth the physical and mental condition of Jean. The original of said affidavit is on file at the Cumberland County Courthouse, Carlisle, Pennsylvania, recorded in Record Book 112, Page 494, Exhibit "A". 6. No change in Jean's disability and physical and mental condition has occurred from 1985 to the present. 7. Jean is the beneficiary under a Testamentary Trust established by her father, George L. Hempt, who died on September 8, 1942, and whose Will is filed with the Cumberland County Register of Wills at No. 2008 of 1942. The Will of George L. Hempt names his brother, Loy T. Hempt (now deceased) as trustee of such Testamentary Trust for the benefit of Jean. By Decree dated April 12, 1977 at No. 253 of 1977, the Cumberland County Court named Max C. Hempt (a brother of Jean) and Dorothy H. Mark (a sister of Jean) as successor trustees of such Testamentary Trust for the benefit of Jean under the Will of George L. Hempt. 8. Jean, also, is a beneficiary of a Testamentary Trust under the Will of her uncle, Loy T. Hempt, now deceased, whose Will is filed with the Cumberland County Register of 2 Exhibit A Wills, at No. 21-77-231. The Will of Loy T. Hempt names Max C. Hempt and Margaret Hempt, the widow of Loy T. Hempt, as trustees of such Testamentary Trust for the benefit of Jean, with provision that at the death of Margaret Hempt (who died September 4, 1988), she will be succeeded as a co -trustee by Dorothy H. Mark. 9. In a Final Decree of the Cumberland County Court dated March 8, 1985 (Book 112, Page 499), Judge Sheely ordered that Jean is judged an incompetent and that Max C. Hempt and Dorothy H. Mark are appointed guardians of Jean's estate, with no bond required. 10. In a Final Decree of the Cumberland County Court dated May 10, 1990, Judge Sheely ordered that Max C. Hempt and Dorothy H. Mark are appointed guardians of the person of Jean, with no bond required. 11. Because of the death of Dorothy H. Mark on June 15, 1995, there now is a vacancy for the fiduciary positions she held as (1) co -trustee with Max C. Hempt of the Testamentary Trust under the Will of George L. Hempt for the benefit of Jean; (2) co -trustee with Max C. Hempt of the Testamentary Trust under the Will of Loy T. Hempt for the benefit of Jean; (3) co -guardian with Max C. Hempt under the Final Decree of the Cumberland County Court, dated March 8, 1985, naming Dorothy H. Mark as a co -guardian with Max C. Hempt of the Estate of Jean; and (4) co -guardian under the Final Decree of the 3 Exhibit .A Cumberland County Court of May 10, 1990 naming Dorothy H. Mark as a co -guardian with Max C. Hempt of the person of Jean. 12. Petitioner Gerald L. Hempt is particularly situated to be a fiduciary for the benefit of Jean because he has been involved for numerous years with overseeing and managing Jean's financial affairs, and from this involvement, Gerald L. Hempt (aside from Petitioner Max C. Hempt) is most knowledgeable about the over-all well-being and welfare of Jean. 13. A major asset held for the benefit of Jean in the subject fiduciary accounts is shares of stock of .Hempt Brothers, Inc., a family owned quarrying and road building business of which both Petitioner Max C. Hempt and Petitioner Gerald L. Hempt are significant shareholders. Because of the prominence of Hempt Brothers, Inc. stock among the assets held for .the benefit of Jean, it is desirable and appropriate that a successor to Dorothy H. Mark as a fiduciary for the benefit of Jean be a person significantly knowledgeable about Hempt Brothers, Inc. Petitioner Gerald L. Hempt particularly qualifies in this respect, because beyond being a shareholder of Hempt Brothers, Inc., he is, also, the long-time Secretary/Treasurer of that Company, and has for numerous years been involved with the management of that Company on a daily basis. 4 Exhibit A 14. Service of notice on Jean about the filing of this Petition, because of her disability, will serve no purpose. 15. Petitioner Gerald L. Hempt is the owner of substantial property in Cumberland and York Counties, and, therefore, it is respectfully submitted that no bond is necessary for his serving as a fiduciary for the benefit of Jean. 16. Appointment of Petitioner Gerald L. Hempt as a co -trustee with Max C. Hempt of Testamentary Trusts for the benefit of Jean, and as a co -guardian with Max C. Hempt of her estate, and of her person, as herein described, is in the best interests of Jean, and such appointment will not adversely affect the interests of any other person or organization. WHEREFOR, your Petitioners pray that Gerald L. Hempt be appointed as a successor co -trustee and as a successor co -guardian, as herein described, for the benefit of Jean, with no bond being required of him. Gerald L. Hempt 5 Exhibit A COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF CUMBERLAND MAX C. HEMPT and GERALD L. HEMPT, being duly sworn according to law, depose and say that the facts set forth in the aforegoing Petition are true and correct to the best of their knowledge, information and belief. Sworn to and subscribed before me this 3 r -d -day of , _ , 1996. My Commission Expires: NOTARIAL SEAL DIANE H. ROY, Notary Public Camp Hill, Cumberland County My Commission Expires Aug. 3, 1998 6 Exhibit A • • " FOUNDED 1913 EY M0WE WOODS HARE out • 2956) • THE WOODS SCHOOLS AND RESIDENTIAL TREATMENT CENTER Langhorne, Pennsylvania 19047 • Telephone 215 757-3731 The undersigned, being duly sworn according to law, deposes and says that he is a licensed physician specializing in Pediatrics and has examined Jean Doris Hempt and is and has been her physician since August, 1982 and deposes and says the following: 1. That I am a Board -Certified Pediatrician, licensed to practice in the State of Pennsylvania. 2. That Jean Doris Hempt entered The Woods Schools on September 13, 1938 and has resided there continuously since that date. 3. That Jean Doris Hempt suffers from mild mental retardation. Her full-scale as measured by the Wechsler Adult Intelligence Scale, is 60. Additionally, she demonstrates deficits in visual -motor integration. She functions on a concrete level, demonstrating difficulty with abstract thought, practical judgement and memory. She is physically well, although she has hypothroidism and varicosities of both legs. 4. That Jean Doris Hempt, because of her mental retardation, is unable to manage her own property, is liable to dissipate it and could well become the victim of designing persons. Lf 4 7 1 , . . .... • .. . !I. C.. , : • '77.3 Stanley Gould, 1.D. EXHIBIT "A"' IN THE MATTER OF JEAN DORIS HEMPT, AN INCOMPETENT COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ORPHANS' COURT DIVISION Nos. 2008 of 1942, 253 of 1977, and 117 of 1985 FINAL DECREE vil AND NOW, this day of S` rr-y'ri''t996, upon consideration of the annexed Petition, IT IS ORDERED AND DECREED that Gerald L. Hempt is hereby appointed: (1) a co -trustee (with Max C. Hempt) of the Testamentary Trust for the benefit of Jean Doris Hempt under the Will of George L. Hempt; (2) a co -trustee (with Max C. Hempt) of the Testamentary Trust for the benefit of Jean Doris Hempt under the Will of Loy T. Hempt; and, (3) a co -guardian (with Max C. Hempt) of the estate, and of the person, of Jean Doris Hempt. BY THE COURT, CC UU 7 Exhibit B TOWNSHIP We ;OWER ALLEN 21-77 11 230 11 ORTHA M. WILLIAMS A-CTA Carrip Hill • WARY 16,1977 ! EXECUTOR c ,j EUXEM` ., DOTH F: Nov :2 1976 ADMR JANET R WILLIAMS BOOK No. PAGE MONTH DAYYEAR ABSTRACT OF PROCEEDINGS Ii BOOK I No. PAGE WILL , 76 355 INV 39 414 TAX • 10 72-4 I • . • i4 mAR. X31 MAY 119 MAY 119 SEPTI OCT MAY110 f 7 1 1977 1977 1977 1977 1977 1979 Petition for Citation „ LETTERS OF ADMINISTRATION-CTA BOND DEDUCTIONS INHERITANCE TAX APPRAISEMENT FEDERAL ESTATE TAX RETURN Rt rexeEAZ,-1 t -- acst BIC_ y p. 1 b '7 0.0 , i1031 WILL !761646 TAX 10 X83-2 �. 911 RESIDENCE ! TOWNSHIP OF ' EAST PENNSB0R0, FILE No. 21-77 231 NAME OF DECEDENT LOiCT-,_HEMPT DESIGNATION T RESIDENCE HAMPDEN TWP. RUARY 24 , 1977 ! MAX HEMPT & 3#1101N3111PIX EXECUTOR DOROTHY HEMPT MARK DATE OF MARCH 19,1977 DEATH ADM•R BOOK No. PAGE I MONTH IDAY1 YEAR ABSTRACT OF PROCEEDINGS BOOK No. PAGE _ 1 WILL76 . 362 TAX •10 ,72-5 11 •Exhibit MAR !31 DEC DEC 119 APR [20 MAY 116 MAY APR 4.2 JAN. '27'1992: ;1977 19119771 ;1977] 16 ;1979 ; 1978` 1978 I J.978 LETTERS TESTAMENTARY- f%,._ v, t: ,j - INVENTORY DEDUCTIONS INHERITANCE TAX APPRAISEMENI' FEDERAL ESTATE TAX RETURN AMENDED FEDERAL ESTATE TAX RETURN REMAINDER APPRAISEMENT LETTERS TESTAMENTARY C _...... - WILL X76 INV 39 TAX ` 10-72-71 i TAX 10 WILL 120708 I II 368 842 . 72-7 I C.A HEMPT ESTATE, INC. VALUATION Assets Cash Bonds Fixed Assets, net of depreciation Deferred Lease expense, net Total Assets Liabilities Demand Note Per CPA Statements 12/31/00 302,309 63,283 1,498,686 25,444 Fair Market Value Sale/ Liquidation Value 302,309 62,873 * Per CPA Statements 5,359,000 ** Per 5/1/01 appraisals 25,444 1,889,722 5,749,626 (675,000) (675,000) Net Asset Value 1,214,722 5,074,626 Going Concern Value Fair Market Value of Assets Tess Iiablities 5,074,626 Discount for lack of marketability (30%) and minority interest (30%) for combined discount of 51 % (2,588,059) Value 2,486,567 Per share value (24,000 shares outstanding) Safe/Liquidation Value 104 Potential gain on sale of real estate (5,359,000 minus 1,498,686) Less: selling expenses (estimated) Potential Toss on sale of bonds (62,873 minus 63,283) Net gain Less: PA tax on gain at 9.99% Gain on sale for Federal tax purposes Federal tax @ 35% Fair Market Value of assets Tess liabilities Less: selling expenses (estimated) PA tax on gain Federal tax on gain Net asset value after sale/liquidation Per share value (24,000 shares outstanding) Exhibit C 3,860,314 (400,000) (410) 3,459,904 (345,644) 3,114,260 1,089,991 5,074,626 (400,000) (345,644) (1,089,991) 3,238,991 135 4 C.A HEMPT ESTATE, INC. Present Value of $5 per share annual dividend for 99 years Interest Rate Present Value $5 per year/99 years Present Value of $135, payable in 99 years Present Value of $135, payable in 99 years 5% 6% 7% 8% $99 $83 $71 $62 $1 $0 $0 $0 Total Value $100 $83 $71 $62 Exhibit C