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Hti _i;S;: t.'I-.r; . ;< 3 f{ -/73/ ," IN RE: ) IN THE COURT OF CO~mON PLEAS OF ) CUMBERLAND COUNTY, PENNSYLVANIA ) ) ORPHANS' COURT DIVISION ) ) FILE NO. 21-78-0683 ESTATE OF GRACE E. HEMPT DECREE AND NOW, this f'l'-day of ~ ' 1981, upon con- sideration of the attached Petition, the prayer of the Petitioner is granted, and a Citation is hereby directed to be issued to the Honorable Mary C. Lewis, Register of wills of Cumberland County, to show cause why the Appeal of Robert H. Kalbach from the Appraisement for inheritance tax purposes dated June 4, 1981, on the Estate of Grace E. Hempt, deceased, should not be sustained, and the inheritance tax be assessed at the appli- cable rates on the clear value of the Estate as shown on Petitioner's Report and Appraisal thereof filed on September 6, 1979. Returnable according to {i~.llur2l; THE COURT: !trj/ d q;3~a.I'b'.~y .~/ ",..V;'; .1J4I ~. 1/ {TV ~ J. CLECKNER a FEAREN ATTORNEYS AY LAW HARRISBURG, PENNSYLVANIA BOOK 108 PAGE 628 . , IN RE: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ESTATE OF GRACE E. HEMPT ORPHANS' COURT DIVISION FILE NO. 21-78-0683 PETITION FOR CITATION SUR APPEAL FROM ASSESSMENT OF INHERITANCE TAX TO THE HONORABLE, THE JUDGES OF THE SAID COURT: AND NOW, comes the Petitioner, Robert H. Kalbach, by his attorneys, Cleckner and Fearen, and files this Petition, averring in support thereof as follows: 1. Your Petitioner, Robert H. Kalbach, 1S an adult individual, residing at 23 Center Drive, Camp Hill, pennsyl- vania, and is the Executor of the Estate of Grace E. Hempt, deceased, who died testate on December 8, 1978, letters testamentary having been granted to him by the Register of Wills of Cumberland County on December 18, 1978. 2. On September 6, 1978, your Petitioner filed his Report and Appraisal of Assets of the said estate and the Statement of Debts and Deductions for Assessment of Inheritance Tax, as required by the Act of June 15, 1961, P.L. 373, No. 207. Included as assets of the said estate in the said Report and Appraisal were 6,000 shares of com- man stock of C. A. Hempt Estate, Inc. The valuation of CLECKNER III FEAREN ATTORNEYS AT LAW HARRJSBURG~ PENNSYLVANIA Baal( 108 fAGE 619 CLECKNER a FEAREN ATTORNEYS AT LAW HARRISBURG. PENNSYLVANIA of these shares is the sole disputed item in this matter and forms the sole basis of this appeal. 3. The said C. A. Hempt Estate, Inc., is a closely held corporation, formed on January 9, 1958, under the laws of the Commonwealth of Pennsylvania, and has 24,000 shares of common stock issued and outstanding, held as follows: a. The Estate of J. F. Hempt (decedent's late brother) - 6,000 shares; b. The Estate of Lay T. Hempt (decedent's late brother) - 6,000 shares; c. The Estate of Grace E. Hempt (decedent) - 6,000 shares; d. Max C. Hempt (decedent's nephew) - 2,000 shares; e. Dorothy Hempt Mark (decedent's niece) - 2,000 shares; f. Trustee for Jean D. Hempt, an incompetent (decedent's niece) - 2,000 shares. 4. The shares of C. A. Hempt Estate, Inc., other than those held by decedent's estate, are owned or controlled by Max C. Hempt in the following manner: a. The personal representative and Trustee of the Estate of J. F. Hempt and the Estate of Lay E. Hempt is Max C. Hempt; 8001< 108 f~GE 620 - 2 - CLECKNER a FEAREN ATTORNEYS AY LAW HARRISBURG, PENNSYLVANIA b. The Trustee for Jean D. Hempt is Max C. Hempt: c. Dorothy Hempt Mark is the daughter of Max C. Hempt. The said Max C. Hempt is a direct business competitor of your Petitioner, the sole beneficiary of decedent's will. 5. The said C. A. Hempt Estate, Inc., has never paid dividends from the date of its incorporation until the present time. 6. The assets of the C. A. Hempt Estate, Inc., consist entirely of real estate, some of which is the subject to long-term lease arrangements at rental rates established in 1958 which extend to the year 1998. 7. On October 12, 1979, your Petitioner filed with the Inheritance Tax Division, Department of Revenue, Commonwealth of Pennsylvania, a Closely Held Corporate Stock Information Report, setting forth the number and estimated value of the shares of C. A. Hempt Estate held by decedent at the date of death. Said Report showed a value of $15.92 per share for the 6,000 shares held by decedent, for a total of $95,520.00. Said valuation was based upon the following: a. The Department of Revenue approved the valuation of a like ownership of 6,000 shares of C. A. Hempt Estate, Inc., of $13.55 per share, as of 800K 108 ~GE 621 March 19, 1977, the date of death of Lay T. Hempt, decedent's late brother. b. Said valuation as of March 19, 1977, was based on the value of the shareholder's equity in the corporation as of that date, of $406,190.07, and included a 20 percent discount to reflect lack of marketability and the minority interest. c. The said Report of your Petitioner likewise valued the 6,000 shares of C. A. Hempt Estate, Inc., held by decedent in the same manner as that approved by the Department of Revenue, based upon the shareholder's equity in the corporation as of the date of death of December 9, 1978, of $477,714.68, and including a 20 percent discount to reflect minority interest and lack of marketability. 8. On July 3, 1980, the appraiser for the Department of Revenue filed an appraisement for the assessment of inheritance tax in which he increased the value of the 6,000 shares of com- man stock of C. A. Hempt Estate, Inc., to $38.55, for a total of $231,314.49. 9. On or about November 10, 1980, the United States CLECKNER III FEAREN Internal Revenue Service appraised the 6,000 shares of common ATTORNEYS AT LAW HARRISBURG, PENNSYLVANIA stock owned by decedent at $19.98 per share based upon the fol- lowing: BOOK 108 PAGE 622 - 4 - CLECKNER a FEAREN ATTORNEYS AT LAW HARRISBURG, PENNSYLVANIA a. The total book value of the corporation was appraised at $959,186.79; b. This value was utilized to determine a per share value of $39.96, less a discount of 50 percent to reflect the minority interest and lack of marketability, for a value of $19.98 per share. 10. On August 29, 1980, your Petitioner filed a protest with the Commonwealth Department of Revenue Board of Appeals protesting the appraisal of the estate as set forth above. On May 27, 1981, the said Board of Appeals issued a decision and order, sustaining the protest in part and adjusting the value of the shares to $31.97 per share for a total of $191,820. Said valuation was based upon the value approved by the United States Internal Revenue Service, but allowed only a 20 percent discount to reflect minority interest and lack of marketability. 11. Said valuation established by the Board of Appeals was adopted by the Register of Wills of Cumberland County ln a Notice of Inheritance Tax Asssessment filed on or about June 4, 1981. 12. Your Petitioner appeals from the act of the Board of Appeals and the Register of Wills, in fixing the value of the said shares at $191,820, averring that the said valuation is 800K 108 PACE 623 - 5 - erroneous for the following reasons: a. Said valuation was arrived at without regard to the fact that Petitioner's valuation was based upon the identical criteria utilized to value the same stock in the Estate of Loy T. Hempt who died 18 months prior to decedent, and which method was approved by the Department of Revenue; b. Said valuation was arrived at without regard to the valuation of the 6,000 shares that was approved by the United States Inter- nal Revenue Service on or about November 10, 1980; c. The said valuation does not take into account the minority nature of the 6,000 shares, their lack of marketability, and the minority interest's inability to force dissolution of the corporation to obtain a pro rata share of the assets or to exert control over the operation of the corpora- tion; d. Said valuation was arrived at without regard to the nature of the assets of the corporation, the terms of the long-term leases which encumber the CLECKNER a FEAREN ATTORNEYS AT LAW HARRISBURG. PENNSYLVANIA real property upon which the income of the corpora- - 6 - 800K 108 fACE 624 CLECKNER a FEAREN ATTORNEYS AT LAW HARRISBURG, PENNSYLVANIA ation is based, low earnings per share of the stock, total absence of dividends during the life of the corporation, and the continuing interest of the person who owns or controls a majority of this stock in maintaining a low level of earnings; e. Said valuation was arrived at without consider- ation of the fact that a majority interest in the stock of the corporation is held or controlled by one in direct business competition with the Petitioner. WHEREFORE, your Petitioner prays that a citation be issued, directed to the Honorable Mary C. Lewis, Register of Wills of Cumberland County, Pennsylvania, to show cause why the appeal of your Petitioner from the appraisement for inheritance tax purposes dated June 4, 1981, with specific reference to the value thereon of the 6,000 shares of common stock of C. A. Hempt Estate, Inc., should not be sustained and the value of the stock reduced to the value shown on the report and appraisal filed by your Petitioner. Respectfully submitted, CLECKNER AND FEAREN By ~:;:;-7~ , Willla. earen, Esquire . (Attorneys for Petitioner) - 7 - BOOK 108 PAGE 625 COMMONWEALTH OF PENNSYLVANIA ) ) SS: COUNTY OF DAUPHIN ) Personally appeared before me, a Notary Public, in and for said Commonwealth and County, ROBERT H. KALBACH, who, being duly sworn according to law, deposes and says that the facts set forth in the foregoing Petition are true and correct to the best of his knowledge. /-^^/?' , //~?//~/~f ;C*~R A (~~0:.A .._._.._~ Robert H. Kalbach Sworn to and subscribed before me this :i( q t:t.. day of :;. -L-<--.,1A...J " , 1981. . ./,; r~~+---,..t -' L"':.(. < .I ,,"\\J: "!leT;" Notary . <:';., ,'\-'O:II~,/J/ ':.~c.?'ts~~"S\ '~[ -0 :(:'~i;'iJ.. ;': ~ ~' . " \~'~~,,::~~is9ion Expires: .; . ../, "'~ ,0;;. ," .' ,,' :.'- '.< 'S )'l '..' tj(; '.. ....'.'. / / "tl'\, '~..f~.;tJ . J j 9 P;J. , ' p U ~" <:/' / ".-"~. t'j,::.:.:;)(>:' (~ . ad A !d 'hL7;~j Publ c CLECKNER a FEAREN ATTORNEYS AT LAW HARRISBURG, PENNSYLVANIA BOOK 108 PAGE 626 CLECKNER III FEAREN ATTORN~YS AT LAW HARRISBURG. PENNSYLVANlA CERTIFICATE OF SERVICE I, John DiClemente, Esquire, hereby certify that I am this 6th day of July, 1981, serving the foregoing Petition for Citation Sur Appeal from Assessment of Inheritance Tax, upon the persons indicated below, by first-class, United States mail, addressed as follows: Department of Revenue Bureau of Field Operations Inheritance Tax Division P. O. Box 2970 Harrisburg, Pa. 17105 CLECKNER AND FEAREN By /,~ .-'\ ,/>./- , . -:;:.? "7. y/I\~,rc ({'~i~ --"E-:~-' p John DiClemente, Esquire 31 North Second Street Harrisburg, Pa. 17101 (Attorneys for Petitioner) BOOK 108 PAGE 627