TIMELINE OF EVENTS Beth R. Tyler, Edward Fleisher, Jessica Sampson

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1 The Federal Estate Tax Return: Dealing with Portability and other Preparation Pointers Philadelphia Bar Association s Probate & Trust Section s Tax Committee May 21, 213 Robert M. Maxwell, Esq. Direct: Director of Estate Tax, Managing Director Facsimilie: The Glenmede Trust Company, N.A. [email protected] 1. Filing the Federal Estate Tax Return a. Extension of Time to Pay b. Extension of Time to File 2. Lifetime gifts and Form 76 a. Duty of executor to inquire as to prior gifts b. Line 4 Worksheet-Adjusted taxable gifts c. Line 7 Worksheet-Total gift tax paid or payable 3. Gallenstein a. Full basis step up of house b. Capital gains when the surviving spouse sells the house. 4. State Death Tax Deduction a. What is deductible? 5. Deceased Spousal Unused Exclusion (DSUE) [Portability] a. Portability for the decedent with a Surviving Spouse i. To which estates does portability apply? ii. How do you elect portability? iii. How do you opt out? b. How do you calculate the amount that is portable? i. What impact of prior gifts? c. Complete and properly prepared Return i. Estimating with the special rule of Treas. Reg T(a)(7)(ii) 6. The Surviving Spouse and the Deceased Spousal Unused Exclusion a. When can the surviving spouse use the DSUE? b. When does the DSUE end? i. last deceased spouse ii. Remarriage, or remarriage and divorce by surviving spouse c. Gift Tax Return of Surviving Spouse d. Federal Estate Tax Return of Surviving Spouse 7. Prior Transfer Credit 1

2 TIMELINE OF EVENTS Beth R. Tyler, Edward Fleisher, Jessica Sampson 12/31/1969 Beth R. Tyler marries Edward Fleisher 1/1/1972 Beth and Edward buy 23 Lowry s Lane, Rosemont, PA -Beth pays all consideration -House titled as tenants-by-the-entireties 2/2/22 Beth gives $1,511, to Michelle Jackson (her sister) -Annual gift tax exclusion is $11, -Gift tax due when lifetime taxable gifts exceed $1,, 4/15/22 Beth files a 22 Gift Tax Return -Pays $21, of Gift Tax 1/5/212 Beth dies -Surviving spouse: Edward Fleisher -Executor: Edward Fleisher -Federal Estate Tax Return due 1/5/212 extended to 4/5/213 -PA Inheritance Tax Return due 1/5/212 extended to 4/5/213 - Gross estate plus adjusted taxable gifts are less than $5,12, Federal filing requirement. -Federal Estate Tax Return filed for portability. $2,659,148 is the Deceased Spousal Unused Exclusion (DSUE) portable to Edward Fleisher for gift and estate tax purposes. 5/2/212 Edward Fleisher marries Jessica Sampson 6/14/212 Edward gives $2,13, to Bubbles Barton (his daughter) -Annual gift tax exclusion is $13, 8/21/212 Jessica Sampson dies 2/2/213 Edward Fleisher dies -Federal Estate Tax Return due 5/21/213 -PA Inheritance Tax Return due 5/21/213 -Federal Estate Tax Return due 11/2/213 -PA Inheritance Tax Return due 11/2/213 2

3 I. THE FEDERAL ESTATE TA RETURN-GENERAL FILING INFORMATION A. WHICH ESTATES MUST FILE A RETURN 1. Gross estate requirement The executor must file a federal estate tax return if the gross estate, plus adjusted taxable gifts and specific exemption is more than the amount shown below: a) 211 deaths-$5,, b) 212 deaths-$5,12, c) 213 deaths-$5,25, (top rate increases to 4%) 2. Portability election The executor must a file a federal estate tax return (regardless of the size of the gross estate), if the executor wants to elect to permit the decedent s surviving spouse to use the decedent s unused exclusion amount. a) The 212 Tax Relief Act (passed January 1, 213) made the portability provisions permanent. (Under the 21 Tax Relief Act, the portability provisions only applied to 211 and 212 decedents.). 3. Unified Credit Against Estate Tax a) A credit of the applicable credit amount shall be allowed to the estate of every decedent against the federal estate tax. I.R.C. 21(a) b) The applicable credit amount is the amount of the tentative tax which would be determined on the applicable exclusion amount. I.R.C. 21(c)(1) c) The applicable exclusion amount is the sum of: (1) The basic exclusion amount ($5,, for 211 deaths; $5,12, for 212 deaths, $5,25, for 213 deaths), AND (2) In the case of a surviving spouse, the deceased spousal unused exclusion amount. I.R.C. 21(c)(2) (3) The deceased spousal unused exclusion amount is the lesser of: (a) The basic exclusion amount ($5,, for 211 deaths; $5,12, for 212 deaths; $5,25, for 213 deaths), OR 3

4 (b) The excess of: (i) The applicable exclusion amount of the last such deceased spouse of such surviving spouse, over (ii) The amount with respect to which the tentative tax is determined on the estate of such deceased spouse. I.R.C. 21(c)(4) d) Prior Gift Tax Paid-For purposes of the Deceased Spousal Unused Exclusion Amount calculation, the amount of adjusted taxable gifts is reduced by the amount of gifts on which gift tax was paid. Treas. Reg T(c)(2) 4. Portability Election a) A deceased spousal unused exclusion amount [ DSUE ] may only be taken into account by a surviving spouse if the executor of the deceased spouse: (1) Timely files (including extensions) a federal estate tax return on which the amount is computed; and (2) Makes an election on the federal estate tax return. I.R.C. 21(c)(5)(A) b) The election is irrevocable. I.R.C. 21(c)(5)(A) (1) A portability election can be superseded by a subsequently filed return, provided that return is filed by the due date of the return. Treas. Reg T(a)(4) c) Deemed election Upon timely filing of a complete and properlyprepared estate tax return, the executor will have elected portability of the DSUE amount unless the executor chooses not to elect portability. Treas. Reg T(a)(2) d) Ways to not make the Portability Election (1) 211 Federal Estate Tax Form (a) Statement-Attach a statement to the return indicating that the estate is not making the election under 21(c)(5); Treas. Reg T(a)(3)(i) 4

5 (b) Write No Election under Section 21(c)(5) across the top of the first page of the federal estate tax return. Instructions for Form 76 (Rev. August 211), p. 13 (c) Do not file a Federal Estate Tax Return (Treas. Reg T(a)(3)(ii) (2) 212 Federal Estate Tax Return (a) See Part 6, Section A. Portability Election e) Complete and Properly-Prepared Requirement (1) A return is complete and properly-prepared if prepared in accordance with the form instructions and the Internal Revenue Code and Regulations. Treas. Reg T(a)(7)(i) (a) Exceptions to reporting requirements where return is being filed for portability election only: (i) For bequests, devises or transfers which are deductible under I.R.C. 256 or 256A (marital deduction property) or I.R.C. 255(a) (charitable deduction property), an executor does not have to report the value for such property and will only need to report: (a) (b) (c) A description of the property; Ownership; The beneficiary; and (d) All information necessary to establish the right of the estate to the estate tax deduction. Treas. Reg T(a)(7)(ii)(A) (ii) Statement required This exception only applies if executor uses due diligence to estimate the fair market value of the estate and attaches a statement indicating that the gross estate is his or her best estimate rounded to the nearest $25,. Treas. Reg T(a)(7)(ii)(B) 5

6 (a) The 212 Form 76 and Instructions provide: f) Computation required for portability election (i) Check box 11 on page 1 if you are estimating the value of assets that qualify for the marital and charitable deductions; (ii) List those assets on the corresponding Federal Estate Tax Schedule without a value; (iii) Using the Table of Estimated Values on page 16 of the Instructions, enter the total value of estimated assets on Part 5, lines 1 and 23 of the Recapitulation on page 3 of Form 76. (1) Transitional Rule (211 Deaths) A complete and properly-prepared estate tax return will be deemed to include the computation of the DSUE amount. Treas. Reg T(b)(2) (2) 212 Form 76 has a calculation of the DSUE amount (See part 6) g) Computing the DSUE Amount (1) In general, the DSUE is the lesser of: (a) The basic exclusion for the year of death of the decedent ($5,, for 211 deaths; $5,12, for 212 deaths; $5,25, for 213 deaths); or (b) The excess of (i) The decedent s applicable exclusion amount; over 6

7 h) Use of DSUE by surviving spouse (ii) The sum of the amount of the taxable estate and the amount of the adjusted taxable gifts of the decedent, which is the amount on which the tentative tax on the decedent s estate is determined. Treas. Reg T(c)(1) (1) The DSUE of the last deceased spouse can be used by the surviving spouse for transfers made after the decedents death (for gifts and on the surviving spouse s federal estate tax return) provided the portability election is made. Treas. Reg T(c) and Treas. Reg T(d) (2) If a surviving spouse makes a taxable gift, the DSUE is applied first before the surviving spouse s own basic exclusion amount. Treas. Reg T(b). (3) The term last deceased spouse means the most recently deceased individual who, at that individual s death after December 31, 21, was married to the surviving spouse. Treas. Reg T(d)(5) (4) If the surviving spouse remarries, or remarries and then gets divorced, the identity of the last deceased spouse remains unchanged for gifts made by the surviving spouse, or on the surviving spouse s federal estate tax return. Treas. Reg T(a)(3); Treas. Reg T(a)(3). (5) With multiple deceased spouses, the special rule is that the DSUE amount available is the DSUE of the surviving spouse s last deceased spouse and the DSUE amount of each other deceased spouse that was applied to taxable gifts made by the surviving spouse. Treas. Reg T(b) and Treas. Reg T(c) 7

8 B. WHEN TO FILE A FEDERAL ESTATE TA RETURN 1. The Federal Estate Tax Return is due within nine months of the decedent s death. I.R.C. 675(a) 2. Extensions in general a) File Form 4768, Application for Extension of Time to File a Return and/or Pay U.S. Estate (and Generation-Skipping Transfer) Taxes 3. Extension of Time to File Form 76 (I.R.C. 681) a) An automatic 6-month extension is allowed if you file form 4768 and check the box. 4. Extension of Time to Pay (Section 6161) a) Extension may not exceed 12 months. b) Attach a written statement showing why it is impossible or impractical to pay the full amount of the tax. (1) Examples of reasonable cause from Treas. Reg (a) Assets needed to pay the tax are located in several jurisdictions and not immediately subject to control of executor. (b) Estate is substantially comprised of rights to receive future payments such as annuities, receivables or royalties. (c) Estate consists of a claim which cannot be collected without litigation. c) Even in an estate where you estimate no federal estate tax will be due, request an extension to pay in case you decide to pay estate tax when the final return is completed. 5. Reasons to extend a federal estate tax return. a) Executor is missing information on assets or deductions. b) Executor is missing a valuation of an asset. c) A substantial asset is listed for sale (such as a house). 8

9 d) The decedent is survived by a spouse there is an opportunity for significant estate planning if the surviving spouse does not live out the extension period. Consider the health of the surviving spouse and the nature of the surviving spouse s assets. e) Does decedent s estate contain a trust or other asset for which a Qualified Terminable Interest Property Election can be made? II. ASSETS REPORTABLE ON THE FEDERAL ESTATE TA RETURN A. REAL ESTATE 1. In General a) The gross estate of a citizen or resident of the United States includes the value of all real property owned by the decedent at the time of his or her death whether it passed directly to heirs or devisees, or came into control of the executor or administrator. Treas. Reg b) Valuation of Real Estate (1) Sales Price If the property is sold after death, value the property at the sales price if it is an arms length transaction. Attach a copy of the settlement sheet as an exhibit to the Return. (a) Expenses of sale of real estate--consider deducting the selling expenses (brokerage fees, etc.) as administration expenses on the federal estate tax return if the sale was necessary for the settlement of the estate. Treas. Reg (d)(2) If the real estate passes by operation of law or specific bequest to a beneficiary, the selling expenses should be the responsibility of the beneficiary and not deductible on the Federal Estate Tax Return. (2) Appraised value If the property is not sold, or is specifically devised to an individual, obtain an appraisal of the property to attach as an exhibit to the return. c) Protective refund claim If property is likely to be sold after the return is filed, consider filing a Protective Refund Claim using Form 843. If the property sells for less than the appraised value on the return, a refund may be appropriate. 2. Schedule A Real estate interests held by the decedent 9

10 a) Schedule A Items include: (1) Land, improvements and fixtures held solely in the name of the decedent. (2) Condominium interests (3) The decedent s tenants in common interest in real property. (4) Real property that the decedent contracted to purchase before his or her death. (Deduct any unpaid purchase monies on Schedule K as a debt). b) Discounts If the decedent owned an undivided fractional interest in property, the appraiser may give a discount attributable to the lower price a willing buyer would pay to purchase a fractional interest in real estate. See Estate of Bonner Sr. v. U.S., 84 F3d 196 (5 th Cir. June 4, 1996) in which the court held that the estate was entitled to a discount of fractional interest discount in real estate and a boat. 3. Schedule E Jointly held real estate a) Property held by husband as wife as tenants by the entireties property, or joint tenants with rights of survivorship is considered a qualified joint interest under I.R.C. 24(b)(2) b) The full value of such property is listed on Schedule E, Part 1. c) Only one half of the full value of the property is included in the decedent s gross estate. I.R.C. 242(b)(1) (1) Subsequent sale of real estate by surviving spouse: The basis of the real estate will only receive one-half step up in basis. (a) EAMPLE: Husband and wife buy real estate in 198 for $3,. Husband dies and the date of death value of the entire property is $45,. Surviving spouse s basis in real estate is $15, (one-half of original purchase price) plus $225, (one-half entitled to step up in basis due to death). Total basis is $24,. If the spouse later sells the property for $6,, the spouse s gain is $36, ($6, selling price less basis of $24,). 1

11 (i) An individual can exclude $25, of gain from sale of principal residence under I.R.C. 121(b)(1) if certain requirements are met. (ii) Husband and wife can exclude $5, of gain from sale of principal residence under I.R.C. 121(b)(2) if certain requirements are met. (iii) Surviving spouse can exclude $5, of gain if house is sold within two years of death of first spouse and certain requirements are met. I.R.C. 121(b)(4) d) ECEPTION: Step up in basis/gallenstein Rule If husband and wife bought real estate prior to 1977 as entireties or survivorship property, and one spouse contributed all consideration to the property, a step up of the entire value of the real estate may be allowed when the contributing spouse dies. See Gallenstein v. U.S., 975 F2d 286 (6 th Cir. 9/16/1992) 4. Real Estate held in Partnerships, or Sole Proprietorships a) Report as part of the value of the partnership or proprietorship on Schedule F. 5. Real Estate held in Trusts a) Report as part of the Trust valuation if the Trust is reportable on Schedule G. b) If the real estate is held in a trust over which the Decedent had a power of appointment, report on Schedule H. B. STOCKS AND BONDS 1. In general 2. Publicly traded stocks and bonds: a) For publicly traded stocks and bonds, the fair market value is the mean between the highest and lowest selling prices quoted on the valuation date. Treas. Reg (1) For stocks provide (a) Number of shares; 11

12 (b) (c) (d) Whether common or preferred; Issue; Par value where needed for identification; (e) Price per share the price per share is the mean value of the high and low on the date of death; (f) Exact name of corporation; (g) Principal exchange upon which sold if listed on an exchange; and (h) Nine-digit CUSIP number; (2) Dividends: List dividends that have not been collected at death and are payable to the decedent or the estate because the decedent was a stockholder of record on the date of death. b) For bonds provide: (1) Quantity and denomination; (2) Name of obligor; (3) Date of maturity; (4) Interest rate; (5) Interest due date; (6) Principal exchange, if listed on an exchange, and (7) Nine-digit CUSIP number. (8) Interest: Include accrued to date of death. 3. For closely held stock, attach the following to the return: a) Copies of complete financial and other data used to determine value, including balance sheets and statements of the net earnings or operating results and dividends paid for each of the 5 years immediately before the valuation date. (Tax returns). b) Valuation from appraiser or methodology used to calculate value. 4. Reporting of stocks and bonds 12

13 a) If stocks and bonds are held in the decedent s name alone, report on Schedule B. b) If stocks and bonds are held as tenants by the entireties or with rights of survivorship by husband and wife, report on Schedule E, Part 1 Qualified Joint Interests Interest held by the Decedent and His or Her spouse as the Only Joint Tenants. c) If stocks and bonds are held jointly with someone other than a surviving spouse, report on Schedule E, Part 2 All Other Joint Interests. d) If stocks and bonds are held in a partnership, report as part of the partnership valuation on Schedule F. e) If stocks and bonds are held as part of a trust, report as part of the trust valuation on Schedule F (Other Miscellaneous Property), Schedule G (Transfers During Decedent s life), or Schedule H (Power of Appointment). f) If stocks and bonds are held in a Payable on Death Account or a Transfer on Death Account or form, list on Schedule G. g) If stocks and bonds are held as part of an Individual Retirement Account, report as part of the IRA valuation on Schedule I-Annuities. C. MORTGAGES, NOTES, AND CASH 1. Mortgages payable to the decedent at the time of death: a) For mortgages and notes, provide the following: (1) Face value, (2) Unpaid balance, (3) Date of mortgage or note, (4) Name of maker, (5) Property mortgaged, (6) Date of maturity, (7) Interest rate, and (8) Interest date. 13

14 b) For contracts by the decedent to sell land report: (1) Name of purchaser, (2) Contract date, (3) Property description, (4) Sale price, (5) Initial payment, (6) Amounts of installment payment, (7) Unpaid balance of principal, and (8) Interest rate. c) For miscellaneous cash items, report: (1) Insurance refunds, (2) Subscription refunds, (3) Cash, coins. d) For bank and money market accounts, report: (1) Name and address of each financial organization, (2) Amount in each account, (3) Account number, (4) Nature of account checking, savings, time deposit, etc., and (5) Unpaid interest accrued from date of last interest payment to the date of death. (6) Bank date of death letters attach bank date of death balance letters to return as an exhibit. (7) Jointly held accounts held between decedent and nonspouse 14

15 (a) The full value of jointly owned property held with anyone other than the spouse must be included on Schedule E, Part 2. All Other Joint Interests, unless: (i) the executor can show that a part of the property originally belonged to the other tenant and was never received by the decedent for less than adequate and full consideration, or (ii) unless the executor can demonstrate that any of the property was acquired with consideration originally belonging to the surviving joint tenant. I.R.C. 24(a) (b) Note Question 1 on Part 4, Page 3 of Form 76: Did the decedent at the time of death own any property as a joint tenant with right of survivorship in which (a) one or more of the other joint tenants was someone other than the decedent s spouse, and (b) less than the full value of the property is included on the return as part of the gross estate? D. LIFE INSURANCE REPORTABLE ON SCHEDULE D: 1. Proceeds of life insurance in which the decedent had any incidents of ownership whether payable to the estate or other beneficiaries are included on Schedule D. I.R.C Incidents of ownership a) The right of the insured or estate to its economic benefits; b) The power to change the beneficiary; c) The power to surrender or cancel the policy; d) The power to assign the policy or revoke an assignment; e) The power to pledge the policy for a loan; f) The power to obtain form the insurer a loan against the surrender value of the policy; and g) A reversionary interest if the value of the reversionary interest was more than 5% of the value of the policy. 15

16 3. Describe the policy by listing: a) The name of the insurance company, and b) The number of the policy. 4. Report the proceeds paid in one lump sum and attach Form 712 obtained from the insurance company. 5. Life Insurance on the Decedent s life which decedent had no incidents of ownership should be listed FOR INFORMATION ONLY on Schedule D. Examples would be life insurance owned by a Life Insurance Trust or a Business. a) Note question 9a on Part 4, Page 2 of Form 76: Was there any insurance on the decedent s life that is not included on the return as part of the gross estate? 6. Life Insurance owned by the Decedent on others should be listed on Schedule F. a) Form 712 should be attached to the return. b) Note question 9b on Part 4, Page 2 of Form 76: Did the decedent own any insurance on the life of another that is not included in the gross estate? E. MISCELLANEOUS PROPERTY REPORTABLE ON SCHEDULE F 1. Business interests and partnerships a) Provide statement of assets and liabilities for the valuation date and for the 5 years before the valuation date. b) Attach statements of net earnings for the same 5 years (tax returns of partnership, Limited Liability Company, or S corporation). c) Provide EIN (Employer Identification Number) of entity. d) Provide valuation of entity. e) Note question 11a on Part 4, Page 3 of Form 76: Did the decedent, at the time of death, own any interest in a partnership (for example, a family limited partnership), an unincorporated business, or a limited liability company; or own any stock in an inactive or closely held corporation? 16

17 f) VALUATION DISCOUNTS FOR BUSINESSES OR PARTNERSHIPS: (1) Note question 11b on Part 4, Page 3 of Form 76: If Yes was the value of any interest owned (from above-see 1a) discounted on this estate tax return? If Yes, the instructions require that the executor attach a statement that identifies the business entity on Schedule F and the discounts taken. (2) Possible discounts (a) (b) Lack of control Lack of marketability 2. Insurance on the life of another (attach Form 712 showing the value) 3. If decedent was a surviving spouse, they may have been the beneficiary of a qualified terminable interest property (QTIP) trust established by the first spouse to die. The value of the trust assets is reportable on Schedule F. I.R.C. 244 Property 4. Rights 5. Royalties 6. Leaseholds 7. Judgments 8. Reversionary or remainder interests 9. Household goods and personal effects, including wearing apparel a) For assets specifically bequeathed to individuals: (1) Report sale value if sold at an arms length transaction (at auction or for appraised value). (2) Report appraised value if not sold. b) For assets that are left to residue of the estate: 1. Livestock (1) Report sale value net of auctioneer or sale commissions or deduct selling expenses as administrative expenses. 17

18 11. Farm machinery 12. Automobiles. F. TRANSFERS DURING THE DECEDENT S LIFE Schedule G 1. Gift taxes paid by the decedent or the estate on gifts made by the decedent or the decedent s spouse within 3 years of death are included in the gross estate. I.R.C. 235(b) 2. Transfers made within 3 years of death that would have been included under I.R.C. 236, 237, 238, or I.R.C. 242 had the decedent retained the interest in the property are included in the gross estate. I.R.C. 235(a). a) Example: Where the decedent transfers ownership of a life insurance policy to another within three years of death, the policy proceeds are included in the decedent s estate because the proceeds would have been included in decedent s estate under I.R.C. 242 had the decedent retained ownership of the policy. 3. Transfers by the decedent in which the decedent retained an interest in the property are included in the gross estate. I.R.C. 236 a) If the decedent transferred property to a trust and retained an income, annuity or unitrust interest in the trust for decedent s life, or for a period that does not end before decedent s death, the value of the trust is included in the gross estate. I.R.C. 236(a) 4. Transfers taking effect at death are included in the decedent s gross estate. I.R.C Revocable transfers are included in the decedent s gross estate. I.R.C a) If the decedent had to right to change, alter, amend, revoke or terminate the enjoyment of the property, the property is included in the decedent s gross estate. b) A Revocable Trust or Totten Trust are revocable transfers included in the decedent s gross estate under I.R.C G. POWERS OF APPOINTMENT SCHEDULE H 1. A general power of appointment is included in the decedent s gross estate. I.R.C

19 a) A general power of appointment is a power held by the decedent exercisable in favor of the decedent, his estate, his creditors, or the creditors of his estate. I.R.C. 241(b) b) The right to withdraw the greater of five percent or $5, from a trust is a general power which is included in the decedent s estate to the extent the power was not exercised by the decedent. I.R.C. 241(b) H. ANNUITIES SCHEDULE I 1. Annuities, pension plans, individual retirement arrangements, purchased commercial annuities and private annuities owned by the decedent are included in the decedent s gross estate. I.R.C. 239 a) The annuity or payment must be receivable by the beneficiary following the death of the decedent. b) The annuity is under a contract or agreement entered into after March 3, c) The annuity was payable to the decedent, for the decedent s life or for a period that did not end before the decedent s death. III. FEDERAL ESTATE TA DEDUCTIONS A. In General For federal estate tax purposes, the value of the taxable estate shall be determined by deducting from the value of the gross estate such amounts 1. For funeral expenses, 2. For administration expenses, 3. For claims against the estate, and 4. For unpaid mortgages on, or any indebtedness in respect of, property where the value of the decedent s interest therein, undiminished by such mortgage or indebtedness, is included in the value of the gross estate, as are allowable under the laws of the jurisdiction, whether within or without the united states, under which the estate is being administered. B. FUNERAL EPENSES SCHEDULE J 1. Funeral expenses are only deductible on Form

20 2. Funeral expenses that (a) are actually expended, (b) are properly allowable out of property subject to claims (probate assets), and (c) satisfy the requirements of Treas. Reg (c) are deductible on Form 76. Treas. Reg Funeral expenses should be reduced by reimbursements such as Social Security or Veterans Administration benefits. 4. Examples of expenses: a) Casket b) Tombstone, monument, mausoleum, burial lot, vault and future care c) Undertaker s Fee d) Flowers provided by the estate e) Food for mourners f) Clothing purchased for burial g) Cost of transportation of the person bringing the body to the place of burial. Treas. Reg h) Transportation of one person to and from the burial site for stone setting i) Obituary cost j) Printing and mailing acknowledgment cards k) Honoraria for rabbi, minister, organist, cantor, etc. C. ADMINISTRATION EPENSES SCHEDULE J 1. In General a) Treas. Reg (a) provides that the deduction for administration expenses is limited to such expenses as are actually and necessarily incurred in the administration of the decedent s estate; that is, in the collection of assets, payment of debts, and distribution of property to the persons entitled to it. Expenditures not essential to the proper settlement of the estate, but incurred for the individual benefit of the heirs may not be taken as deductions. 2

21 b) Estate Tax versus Income Tax Deduction (1) Administrative expenses under I.R.C. 253 or 254 can be claimed either as (i) deductions from the decedent s gross estate for federal estate tax purposes under I.R.C. 253, or (ii) as deductions in computing the taxable income of the estate or as an offset against the sales price of property in determining gain or loss. I.R.C. 642(g) Administrative expenses cannot be taken on both returns. (2) An estate may claim the administration expenses as income tax deductions if it files, in duplicate, a statement with the Internal Revenue Service waiving its right to claim them as estate tax deductions. Treas. Reg (g)-1 (3) Exception to Disallowance of Double Deductions: Taxes, interest, business expenses, and other items accrued at date of death are deductible from the gross estate under I.R.C. 253(a)(3) as claims against the estate are also deductible from gross income under I.R.C. 692(b) as deductions in respect of a decedent for income tax purposes. Treas. Reg (g)-2 (4) Portability Administrative expenses deducted on the federal estate tax return will increase the amount of the deceased spousal unused exclusion amount that can shield a surviving spouse s estate from estate tax, but the deductions cannot then be used as income tax deductions on the fiduciary income tax return of the estate. c) Protective Claim for Refund Treas. Reg (d)(5)(i) (1) A protective claim for refund may be filed to preserve the estate s right to claim a refund by reason of claims or expenses that are not paid or do not otherwise meet the section 253 deductibility requirements. Treas. Reg (d)(5)(1) (a) Rev. Proc (1/14/11) sets forth the procedure for a 253 Protective Claim for Refund (i) Time period for filing: The later of 3 years of return filing, or 2 years from tax payment. (ii) Requirements of claim: Set forth grounds and facts for refund under penalties of Perjury. 21

22 (iii) How to File 253 Protective Claim for Refund : (a) For deaths on or after January 1, 212: Schedule PC or Form 843 (iv) Notification for Consideration The executor must notify the IRS that the issue is resolved for the IRS to consider the Protective Claim for Refund.: (a) For deaths on or after January 1, 212: Supplemental Form 76, or Form 843 (b) See Schedule PC attached to 212 Form 76 Protective Claim for Refund. d) TYPES OF ADMINISTRATION EPENSES (1) Executor s Commisions Under Treas. Reg (b)(1), a deduction is allowed for commissions in accordance with the usually accepted standards and practice of allowing such an amount in estates of similar size and character in the jurisdiction in which the estate is being administered. (2) Attorney s Fees Under Treas. Reg (c)(1) attorney fees may not exceed a reasonable remuneration for the services rendered, taking into account the size and character of the estate, the law and practice in the jurisdiction in which the estate is being administered, and the skill and expertise of the attorney. (3) A deduction is allowed for attorney and executor fees not paid at the time of filing of the return provided the amount is ascertainable with reasonable certainty and will be paid. Treas. Reg (d)(4) (4) Miscellaneous administration expenses include: (a) (b) (c) (d) Court costs, Probate fees, Surrogate s fees, Accountants fees 22

23 (e) Appraisers fees (f) Expenses to preserve and distribute estate assets including storing property of the estate. (g) Expenses of sale of property such as real estate or personal property if the sale is necessary to pay the decedent s debts, expenses of administration, or taxes, to preserve the estate, or to effect distribution. Treas. Reg (d)(2) D. DEBTS OF DECEDENT AND MORTGAGES AND LIENS SCHEDULE K 1. Personal liabilities imposed by law, or arising out of contracts or torts, which exist at the time of decedent s death which are bona fide enforceable claims that are actually paid by the estate, or are unpaid but are ascertainable are listed on Schedule K. Treas. Reg Unpaid income taxes are allowable debts under Treas. Reg (f) 3. Unpaid gift taxes are allowable debts under Treas. Reg (d) 4. Medical care expenses paid by the estate within one year beginning with the day after death can be taken as I.R.C. 253 federal estate tax deductions, or as I.R.C. 213(c) income tax deductions on the Decedent s final income tax return, but not both. a) In order to take the income tax deduction, a statement must be filed with the income tax return that the amount has not been allowed as a I.R.C. 253 deduction and waiving the right to having the deduction be allowed as an estate tax deduction. I.R.C. 213(c)(2) b) 7.5% adjusted gross income limit An estate tax deduction is not allowed for that portion of medical expenses disallowed by the 7.5% AGI income tax limitation. Rev. Rul , , CB An unpaid charitable pledge may be deductible on the federal estate tax return under Treas. Reg if: a) The liability was contracted bona fide and for adequate and full consideration in cash or its equivalent, or b) It would be allowed as a charitable deduction under I.R.C

24 6. Property taxes are not deductible unless accrued before the decedent s death. Treas. Reg (b) E. MORTGAGES AND LIENS SCHEDULE K 1. Unpaid mortgages, including interest which accrued to decedent s death are deductions listed on Schedule K. Treas. Reg F. NET LOSSES DURING ADMINSTRATION SCHEDULE L 1. A deduction is allowed on Schedule L for losses due to casualties occurring during the settlement of the decedent s estate including losses from fires, storms, shipwrecks and theft. I.R.C The deduction may be made, in the alternative, on the estate s fiduciary income tax return if the estate has waived its right to take a deduction for such loss. I.R.C. 642(g) 3. Amounts recovered by insurance reduce the deduction. Treas. Reg G. EPENSES INCURRED IN ADMINISTERING PROPERTY NOT SUBJECT TO CLAIMS SCHEDULE L 1. Expenses incurred in administering property in a decedent s gross estate, but not subject to claims may be allowed as deductions. Treas. Reg Examples of such expenses include: a) Expenses incurred in administering a Revocable Trust established by the decedent during his or her lifetime such as attorney and trustee fees. b) Expenses and costs incurred in connection with the collection, valuation and distribution of non-probate assets. H. BEQUESTS, ETC. TO A SURVIVING SPOUSE SCHEDULE M 1. A marital deduction is allowed for any property interest which passes to the surviving spouse, but only to the extent that the interest is included in the gross estate. I.R.C. 256(a) 2. The value of the marital deduction is reduced by any estate, succession, legacy, or inheritance taxes paid out of such property. I.R.C. 256(b)(4) 3. Items passing to surviving spouse outright or by operation of law: 24

25 a) Bequests and devises I.R.C. 256(c)(1) b) Items inherited by surviving spouse I.R.C. 256(c)(2) c) Dower or curtesy interests I.R.C. 256(c)(3) d) Interest transferred to spouse at any time I.R.C. 253(c)(4) e) Jointly held property with right of survivorship. 256(c)(5) f) Property over which decedent had power of appointment or which was appointed to spouse, or passes to spouse in default of appointment I.R.C. 256(c)(6) 4. Trusts for which the marital deduction may be allowed a) Life estate with power of appointment in surviving spouse If the surviving spouse (a) is the only beneficiary during his or her life, (b) receives all income for life, and (c) has a general power of appointment, the trust will qualify for the marital deduction under I.R.C. 256(b)(5) b) Charitable remainder trusts where spouse is only lifetime beneficiary (1) Marital Deduction: allowed for spouse s interest. I.R.C. 256(b)(8) (2) Charitable Deduction: allowed for charitable remainder. 255 c) QTIP (Qualified Terminable Interest Property) Trusts I.R.C. 256(b)(7) (1) Requirements: (a) Property must pass from decedent; (b) Surviving spouse must have a qualifying income interest for life : (i) Surviving spouse must be entitled to all income and be the only beneficiary during his or her lifetime. (ii) QTIP election made on the Federal Estate Tax Return. I.R.C. 256(b)(7)(B) 25

26 I. CHARITABLE, PUBLIC, AND SIMILAR GIFTS AND BEQUESTS SCHEDULE O 1. I.R.C. 255 allows for a deduction from the gross estate of the amount of all bequests, legacies, devises, or transfers to the following entities: a) The United States, any State, any political division of a state, or the District of Columbia for exclusively public purposes. b) Religious, charitable, scientific, literary, or educational corporations or associations. c) Trusts or trustees, or fraternal societies for religious, charitable, scientific, literary, or educational purposes, or for prevention of cruelty to children or animals. d) Veterans organizations. 2. Charitable Remainder Trusts Under I.R.C. 255(e)(2)(A), no charitable deduction is allowed for a remainder interest which will pass to charity unless the interest is in the form of a: a) A charitable remainder annuity trust b) A charitable remainder trust I.R.C. 664 c) A pooled income fund is in the form of a charitable remainder a charitable remainder interest unless I.R.C. 642(c)(5) 3. Payment of death taxes The amount of the charitable deduction is reduced by any estate, succession, legacy, or inheritance taxes required to be paid out of the bequest by the terms of the will or local law. I.R.C. 255(c) 26

27 IV. DEDUCTION FOR STATE DEATH TAES I.R.C. 258 for Decedents dying after January 1, 25 A. I.R.C. 258(a) Allowance of deduction. For purposes of the tax imposed by section 21 (Federal Estate Tax), the value of the taxable estate shall be determined by deducting from the value of the gross estate the amount of any estate, inheritance, legacy, or succession taxes actually paid to any State or the District of Columbia, in respect of any property included in the gross estate (not including any such taxes paid with respect to the estate of a person other than the decedent). B. Actually paid Requirement 1. The state death taxes must be actually paid within the Period of Limitations. I.R.C. 258(b) 2. Pennsylvania s 5% discount on inheritance tax paid within three months of death is not actually paid. C. In respect of any property included in the gross estate 1. The deduction should not be allowed for items subject to Pennsylvania inheritance tax that are not included in the federal gross estate: a) Gifts within one year of death A gift made within one year of death is subject to Pennsylvania Inheritance Tax, but may not be included in the federal gross estate. b) Sole use trusts At the death of the first spouse to die, the Executor can defer the Pennsylvania inheritance tax on a sole use trust for the surviving spouse s benefit until the death of the surviving spouse. When the surviving spouse dies, the trust may not be included in the surviving spouse s federal gross estate depending upon the terms of the trust, and the elections made by the executors of the first spouse to die. D. IRS Form 76 for Report state death tax deduction on page 1, line 3b 2. File with return: a) Certificate from state showing: (1) Total amount of tax imposed; (2) Amount of discount allowed; 27

28 (3) Amount of penalties and interest imposed or charged; (4) Total amount actually paid in cash; and (5) Date of payment. V. GIFT TA RETURNS FILED BY THE DECEDENT A. Calculation of Federal Estate Tax Impact of Taxable Gifts 1. The federal estate tax is calculated by calculating a tentative tax and then applying various credits. a) The tentative tax is calculated on the sum of the taxable estate and adjusted taxable gifts over the aggregate amount of tax which would have been payable under chapter 12 with respect to gifts made by the decedent after December 31, 1976 as if the tax rate in effect at the decedent s death is used to calculate the gift tax and credit against such tax [ Total gift tax paid or payable with respect to gifts made by the decedent after December 31, 1976 ]. I.R.C. 21(b) b) The taxable estate is the gross estate on page 1, line 1, less total allowable deductions on line 2, less the State death tax deduction on line 3b. c) Adjusted taxable gifts are calculated using Worksheet TG Taxable Gift Reconciliation. d) The Total gift tax paid or payable with respect to gifts made by the decedent after December 31, 1976 is calculated using the Line 7 Worksheet. B. Copies of all gift tax returns filed by the Decedent must be filed with the 76. The executor will need copies of all gift tax returns to complete the Line 4 and Line 7 Worksheets. C. Adjusted taxable gifts Line 4 of page 1 of the return. 1. Worksheet TG Taxable Gift Reconciliation a) The executor needs copies of all of the decedent s gift tax returns (Forms 79) to complete Worksheet TG Taxable Gifts Reconciliation. b) If any Gift Tax Returns were audited by the IRS, the executor should use amounts that were finally determined as a result of the audit. 28

29 c) The executor must make reasonable effort as to the existence of any gifts in excess of the annual exclusion made by the decedent for which no Forms 79 were filed (Instructions for Form 76 (Rev. August 212), page 6). Any unreported gifts should be listed in column b of Worksheet TG. (1) Reasonable Effort (a) Review statements for banks, trusts and other accounts from which decedent could have made gifts. (b) Review cancelled checks and bank statements. (c) Keep copies of such records in case Federal Estate Tax Return is audited as auditor may review the statements for gifts. (2) Annual gift tax exclusion amounts: (a) (b) (c) (d) (e) $3, per donee $1, per donee $11, per donee $12, per donee 29 to $13, per donee D. Line 7 Worksheet 1. The executor must carefully follow the instructions of the Line 7 Worksheet. 2. Line 7 is NOT simply the total of all gift tax paid by the decedent during his or her lifetime. 3. The Line 7 worksheet forces the executor to recalculate the gift tax as if the tax rate in effect at the decedent s death is used to calculate the gift tax and credit against such tax. I.R.C. 21(g) E. Example Emma Alden Form 76 29

30 1. In 1996, Emma Alden made a cash gift of $2,12, to her son, Edward Alden. The annual gift tax exclusion for 1996 was $12,. Emma filed 1996 Form 79 reporting a taxable gift of $2,, ($2,12, less the annual gift tax exclusion of $12,) and paid gift tax of $588,. 2. Line 4 Worksheet -- $2,, of adjusted taxable gifts are added to Line 4, page Line 7 Worksheet Even though Emma paid $588, of gift tax when she made the 1996 gift, the Line 7 Worksheet only allows $49, on line 7 Total gift tax paid or payable with respect to gifts made by the decedent after December 31, VI. PRIOR TRANSFER CREDIT SCHEDULE Q A. A credit against the federal estate tax is allowed for the amount of federal estate tax paid with respect to the transfer of property to the decedent by or from a person ( transferor ) who died within 1 years before, or within 2 years after the decedent s death. I.R.C. 213 B. There is no requirement that the property be identified in the estate of the transferee or that it exist on the date of the transferee s death. C. The transfer of the property must have been subjected to federal estate tax in the estate of the transferor. D. Where the transferor predeceased the transferee, the credit is reduced by the time elapsed between dates of death: 1. 1% credit if time elapsed is less than 2 years. 2. 8% credit if time is between 2 years, and less than 4 years. 3. 6% credit if time is between 4 years, and less than 6 years. 4. 4% credit if time is between 6 years, and less than 8 years. 5. 2% credit if time is between 8 years and 1 years. 6. No credit if greater than 1 years. E. Carefully complete the Schedule Q Worksheet using numbers from the Federal Estate Tax Return of the Transferor. 3

31 Form 79 United States Gift (and Generation-Skipping Transfer) Tax Return (Section 619 of the Internal Revenue Code) (For gifts made during calendar year 22) Department of the Treasury Internal Revenue Service See separate instructions. 1 Donor s first name and middle initial 2 Donor s last name Part 1 General Information Attach check or money order here. 3 Donor s social security number Beth Tyler OMB No Address (number, street, and apartment number) 5 Legal residence (domicile) (county and state) 23 Lowry's Lane Delaware County, PA 6 City, state, and ZIP code 7 Citizenship Rosemont, PA If the donor died during the year, check here and enter date of death,. 9 If you received an extension of time to file this Form 79, check here and attach the Form 4868, 2688, 235, or extension letter 1 Enter the total number of donees listed on Schedule A count each person only once. 1 11a 11b Have you (the donor) previously filed a Form 79 (or 79-A) for any other year? If the answer is "No," do not complete line 11b If the answer to line 11a is "Yes," has your address changed since you last filed Form 79 (or 79-A)? 12 Gifts by husband or wife to third parties. Do you consent to have the gifts (including generation-skipping transfers) made by you and by your spouse to third parties during the calendar year considered as made one-half by each of you? (See instructions.) (If the answer is Yes, the following information must be furnished and your spouse must sign the consent shown below. If the answer is No, skip lines and go to Schedule A.) 13 Name of consenting spouse 14 SSN 15 Were you married to one another during the entire calendar year? (see instructions) 16 If the answer to 15 is No, check whether married divorced or widowed, and give date (see instructions) 17 Will a gift tax return for this calendar year be filed by your spouse? 18 Consent of Spouse I consent to have the gifts (and generation-skipping transfers) made by me and by my spouse to third parties during the calendar year considered as made one-half by each of us. We are both aware of the joint and several liability for tax created by the execution of this consent. Consenting spouse s signature Date 1 Enter the amount from Schedule A, Part 3, line Enter the amount from Schedule B, line Total taxable gifts (add lines 1 and 2) 3 4 Tax computed on amount on line 3 (see Table for Computing Tax in separate instructions) 4 5 Tax computed on amount on line 2 (see Table for Computing Tax in separate instructions) 5 6 Balance (subtract line 5 from line 4) 6 7 Maximum unified credit (nonresident aliens, see instructions) 7 8 Enter the unified credit against tax allowable for all prior periods (from Sch. B, line 1, col. C) 8 9 Balance (subtract line 8 from line 7) 9 1 Enter 2% (.2) of the amount allowed as a specific exemption for gifts made after September 8, 1976, and before January 1, 1977 (see instructions) 1 11 Balance (subtract line 1 from line 9) Unified credit (enter the smaller of line 6 or line 11) Credit for foreign gift taxes (see instructions) 13 Part 2 Tax Computation 14 Total credits (add lines 12 and 13) 15 Balance (subtract line 14 from line 6) (do not enter less than zero) 16 Generation-skipping transfer taxes (from Schedule C, Part 3, col. H, Total) 17 Total tax (add lines 15 and 16) 18 Gift and generation-skipping transfer taxes prepaid with extension of time to file 19 If line 18 is less than line 17, enter balance due (see instructions) 2 If line 18 is greater than line 17, enter amount to be refunded 2 Sign Here Yes No 1,5, 1,5, 555,8 555,8 345,8 345,8 Under penalties of perjury, I declare that I have examined this return, including any accompanying schedules and statements, and to the best of my knowledge and belief, it is true, correct, and complete. Declaration of preparer (other than donor) is based on all information of which preparer has any knowledge. Signature of donor Preparer s signature Paid Preparer s Firm s name (or Use Only yours if self-employed), address, and ZIP code Phone no. ( ) For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see page 12 of the separate instructions for this form. Cat. No M 31 USA Date Date 22 Check if self-employed 345,8 345,8 345,8 21, 21, 21, Form 79 (22)

32 Form 79 (22) SCHEDULE A Computation of Taxable Gifts (Including Transfers in Trust) A Does the value of any item listed on Schedule A reflect any valuation discount? If the answer is Yes, see instructions Yes No B Check here if you elect under section 529(c)(2)(B) to treat any transfers made this year to a qualified state tuition program as made ratably over a 5-year period beginning this year. See instructions. Attach explanation. Part 1 Gifts Subject Only to Gift Tax. Gifts less political organization, medical, and educational exclusions see instructions A Item number 1 B Donee s name and address Relationship to donor (if any) Description of gift If the gift was made by means of a trust, enter trust s EIN and attach a description or copy of the trust instrument (see instructions) If the gift was of securities, give CUSIP number C Donor s adjusted basis of gift D Date of gift E Value at date of gift Page 2 Michelle Jackson (sister) 1,511, 2/2/22 1,511, 1 Sometimeland Ranch Simi, California Cash gift Total of Part 1 (add amounts from Part 1, column E) Part 2 Gifts That are Direct Skips and are Subject to Both Gift Tax and Generation-Skipping Transfer Tax. You must list the gifts in chronological order. Gifts less political organization, medical, and educational exclusions see instructions. (Also list here direct skips that are subject only to the GST tax at this time as the result of the termination of an estate tax inclusion period. See instructions.) 1,511,. A Item number B Donee s name and address Relationship to donor (if any) Description of gift If the gift was made by means of a trust, enter trust s EIN and attach a description or copy of the trust instrument (see instructions) If the gift was of securities, give CUSIP number C Donor s adjusted basis of gift D Date of gift E Value at date of gift 1 Total of Part 2 (add amounts from Part 2, column E) Part 3 Taxable Gift Reconciliation 1 Total value of gifts of donor (add totals from column E of Parts 1 and 2) 1 2 One-half of items attributable to spouse (see instructions) 2 3 Balance (subtract line 2 from line 1) 3 4 Gifts of spouse to be included (from Schedule A, Part 3, line 2 of spouse s return see instructions) 4 If any of the gifts included on this line are also subject to the generation-skipping transfer tax, check here and enter those gifts also on Schedule C, Part 1. 5 Total gifts (add lines 3 and 4) 5 6 Total annual exclusions for gifts listed on Schedule A (including line 4, above) (see instructions) 6 7 Total included amount of gifts (subtract line 6 from line 5) 7 Deductions (see instructions) 8 Gifts of interests to spouse for which a marital deduction will be claimed, based on items of Schedule A 8 9 Exclusions attributable to gifts on line Marital deduction subtract line 9 from line Charitable deduction, based on items less exclusions Total deductions add lines 1 and Subtract line 12 from line Generation-skipping transfer taxes payable with this Form 79 (from Schedule C, Part 3, col. H, Total) Taxable gifts (add lines 13 and 14). Enter here and on line 1 of the Tax Computation on page 1 15 (If more space is needed, attach additional sheets of same size.) 1,511, 1,511, 1,511, 11, 1,5, 1,5, Form 79 (22) 32

33 Form 79 (22) SCHEDULE A Computation of Taxable Gifts (continued) Page 3 16 Terminable Interest (QTIP) Marital Deduction. (See instructions for line 8 of Schedule A.) If a trust (or other property) meets the requirements of qualified terminable interest property under section 2523(f), and a. The trust (or other property) is listed on Schedule A, and b. The value of the trust (or other property) is entered in whole or in part as a deduction on line 8, Part 3 of Schedule A, then the donor shall be deemed to have made an election to have such trust (or other property) treated as qualified terminable interest property under section 2523(f). If less than the entire value of the trust (or other property) that the donor has included in Part 1 of Schedule A is entered as a deduction on line 8, the donor shall be considered to have made an election only as to a fraction of the trust (or other property). The numerator of this fraction is equal to the amount of the trust (or other property) deducted on line 1 of Part 3, Schedule A. The denominator is equal to the total value of the trust (or other property) listed in Part 1 of Schedule A. If you make the QTIP election (see instructions for line 8 of Schedule A), the terminable interest property involved will be included in your spouse s gross estate upon his or her death (section 244). If your spouse disposes (by gift or otherwise) of all or part of the qualifying life income interest, he or she will be considered to have made a transfer of the entire property that is subject to the gift tax (see Transfer of Certain Life Estates on page 4 of the instructions). 17 Election Out of QTIP Treatment of Annuities Check here if you elect under section 2523(f)(6) NOT to treat as qualified terminable interest property any joint and survivor annuities that are reported on Schedule A and would otherwise be treated as qualified terminable interest property under section 2523(f). (See instructions.) Enter the item numbers (from Schedule A) for the annuities for which you are making this election SCHEDULE B Gifts From Prior Periods If you answered Yes on line 11a of page 1, Part 1, see the instructions for completing Schedule B. If you answered No, skip to the Tax Computation on page 1 (or Schedule C, if applicable). A Calendar year or calendar quarter (see instructions) B Internal Revenue office where prior return was filed C Amount of unified credit against gift tax for periods after December 31, 1976 D Amount of specific exemption for prior periods ending before January 1, 1977 E Amount of taxable gifts NONE 1 Totals for prior periods Amount, if any, by which total specific exemption, line 1, column D, is more than $3, Total amount of taxable gifts for prior periods (add amount, column E, line 1, and amount, if any, on line 2). (Enter here and on line 2 of the Tax Computation on page 1.) (If more space is needed, attach additional sheets of same size.) 2 3 Form 79 (22) 33

34 Form 79 (22) Page 4 SCHEDULE C Computation of Generation-Skipping Transfer Tax Note: Inter vivos direct skips that are completely excluded by the GST exemption must still be fully reported (including value and exemptions claimed) on Schedule C. Part 1 Generation-Skipping Transfers A Item No. (from Schedule A, Part 2, col. A) In column C, enter the item number of each S- gift in the order it appears in column A of your spouse s Schedule A, Part 2. We have S- preprinted the prefix S- to distinguish your S- spouse s item numbers from your own when you complete column A of Schedule C, S- Part 3. S- In column D, for each gift, enter the amount reported in column C, Schedule C, Part 1, of S- your spouse s Form 79. S- Part 2 GST Exemption Reconciliation (Section 2631) and Section 2652(a)(3) Election Check box if you are making a section 2652(a)(3) (special QTIP) election (see instructions) Enter the item numbers (from Schedule A) of the gifts for which you are making this election 1 B Value (from Schedule A, Part 2, col. E) Maximum allowable exemption (see instructions) C Split Gifts (enter 1 2 of col. B) (see instructions) If you elected gift splitting and your spouse was required to file a separate Form 79 Split gifts from (see the instructions for Split Gifts ), you spouse s Form 79 (enter item number) must enter all of the gifts shown on Schedule A, Part 2, of your spouse s Form 79 here. S- D Subtract col. C from col. B Value included from spouse s Form 79 E Nontaxable portion of transfer Nontaxable portion of transfer 1 F Net Transfer (subtract col. E from col. D) Net transfer (subtract col. E from col. D) 1,1, 2 Total exemption used for periods before filing this return 3 Exemption available for this return (subtract line 2 from line 1) 2 3 1,1, 4 Exemption claimed on this return (from Part 3, col. C total, below) 5 Exemption allocated to transfers not shown on Part 3, below. You must attach a Notice of Allocation. (See instructions.) Add lines 4 and Exemption available for future transfers (subtract line 6 from line 3) Part 3 Tax Computation A Item No. (from Schedule C, Part 1) B Net transfer (from Schedule C, Part 1, col. F) C GST Exemption Allocated D Divide col. C by col. B E Inclusion Ratio (subtract col. D from 1.) F Maximum Estate Tax Rate 1 5% (.5) 2 5% (.5) 3 5% (.5) 4 5% (.5) 5 5% (.5) 6 5% (.5) 5% (.5) 5% (.5) 5% (.5) 5% (.5) Total exemption claimed. Enter here and on line 4, Part 2, above. May not exceed line 3, Part 2, above (If more space is needed, attach additional sheets of same size.) G Applicable Rate (multiply col. E by col. F) Total generation-skipping transfer tax. Enter here, on line 14 of Schedule A, Part 3, and on line 16 of the Tax Computation on page 1 7 1,1, H Generation-Skipping Transfer Tax (multiply col. B by col. G) Form 79 (22) 34

35 Form 76 United States Estate (and Generation-Skipping (Rev. August 212) Transfer) Tax Return OMB No Department of the Treasury Internal Revenue Service Part 1 - Decedent and Executor Part 2 - Tax Computation 1a 3a 6a 6c 7a I Estate of a citizen or resident of the United States (see instructions). To be filed for I decedents dying after December 31, 211, and before January 1, 213. Information about Form 76 and its separate instructions is at Decedent's first name and middle initial (and maiden name, if any) 1b Decedent's last name 2 Decedent's social security no. County, state, and ZIP or foreign country and postal code, of legal residence (domicile) at time of death Name of executor (see instructions) Executor's social security number (see instructions) 3b Year domicile established 4 Date of birth 5 Date of death 6b Executor's address (number and street including apartment or suite no.; city, town, or post office; state; country; and ZIP or postal code) and phone no. Phone no. 6d If there are multiple executors, check here and attach a list showing the names, addresses, telephone numbers, and SSNs of the additional executors. Name and location of court where will was probated or estate administered 7b Case number I I 8 If decedent died testate, check here and attach a certified copy of the will. 9 If you extended the time to file this Form 76, check here 1 If Schedule R-1 is attached, check here 11 If you are estimating the value of assets included in the gross estate on line 1 pursuant to the special rule of Reg. section T(a) (7)(ii), check here 1 Total gross estate less exclusion (from Part 5 - Recapitulation, item 13) mmmmmmmmmmmmmmmmmm 1 3,535,925 2 Tentative total allowable deductions (from Part 5 - Recapitulation, item 24) mmmmmmmmmmmmmmmm 2 2,74,114 3a Tentative taxable estate (subtract line 2 from line 1) mmmmmmmmmmmmmmmmmmmmmmmmmmm 3a 1,461,811 b State death tax deduction mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 3b 959 c Taxable estate (subtract line 3b from line 3a) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 3c 1,46,852 4 Adjusted taxable gifts (see instructions) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 4 1,5, 5 Add lines 3c and 4mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 5 2,96,852 6 Tentative tax on the amount on line 5 from Table A in the instructions mmmmmmmmmmmmmmmmmm 6 1,17,98 7 Total gift tax paid or payable (see instructions) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 7 175, 8 Gross estate tax (subtract line 7 from line 6) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 8 842,98 9a Basic exclusion amount mmmmmmmmmmmmmmmmmmmmmm 9a 5,12, 9b Deceased spousal unused exclusion (DSUE) amount from predeceased spouse(s), if any (from Section D, Part 6-Portability of Deceased Spousal Unused Exclusion) mmmmmm 9b 9c Applicable exclusion amount (add lines 9a and 9b) mmmmmmmmm 9c 5,12, 9d Applicable credit amount (tentative tax on the amount in 9c from Table A in the instructions) 9d 1,772,8 1 Adjustment to applicable credit amount (May not exceed $6,. See instructions.) mmmmmmmmmmmmmmmmmmmmmmmmmm 1 11 Allowable applicable credit amount (subtract line 1 from line 9d) mmmmmmmmmmmmmmmmmmmm 11 1,772,8 12 Subtract line 11 from line 8 (but do not enter less than zero) mmmmmmmmmmmmmmmmmmmmmmm Credit for foreign death taxes (from Schedule P). (Attach Form(s) 76-CE.) mmm Credit for tax on prior transfers (from Schedule Q) mmmmmmmmmm Total credits (add lines 13 and 14) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Net estate tax (subtract line 15 from line 12) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Generation-skipping transfer (GST) taxes payable (from Schedule R, Part 2, line 1) mmmmmmmmmmmm Total transfer taxes (add lines 16 and 17) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Prior payments (explain in an attached statement) mmmmmmmmmmmmmmmmmmmmmmmmmmmm 19 2 Balance due (or overpayment) (subtract line 19 from line 18) mmmmmmmmmmmmmmmmmmmmmmm 2 Under penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements, and to the best of my knowledge and belief, it is true, correct, and complete. Declaration of preparer other than the executor is based on all information of which preparer has any knowledge. Sign Here Beth R Delaware County Edward Fleisher Paid Preparer Use Only M M Signature of executor Signature of executor Print/Type preparer's name Firm's name Firm's address I PA 191- Preparer's signature Tyler Date M M Date Date Check if self-employed Firm's EIN Phone no. For Privacy Act and Paperwork Reduction Act Notice, see instructions. Form 76 (Rev ) JSA 1R81 1. I /9/1921 1/5/212 c/o Rosemont Trust Company 1 Main Street Rosemont, PA 191 Orphans Court of Delaware County, Pennsylvania ( ) - PTIN I I

36 Form 76 (Rev ) Decedent's social security number Estate of: Beth R Tyler Part 3 - Elections by the Executor Note. For information on electing portability of the decedent's DSUE amount, including how to opt out of the election, see Part 6- Portability of Deceased Spousal Unused Exclusion. Note. Some of the following elections may require the posting of bonds or liens. Please check the "Yes" or "No" box for each question (see instructions). 1 Do you elect alternate valuation? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 2 Do you elect special-use valuation? If "Yes," you must complete and attach Schedule A-1 mmmmmmmmmmmmmmmmmmmm 3 Do you elect to pay the taxes in installments as described in section 6166? mmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," you must attach the additional information described in the instructions. Note. By electing section 6166 installment payments, you may be required to provide security for estate tax deferred under section 6166 and interest in the form of a surety bond or a section 6324A lien. 3 4 Do you elect to postpone the part of the taxes due to a reversionary or remainder interest as described in section 6163? 4 mmmmm Part 4 - General Information Note. Please attach the necessary supplemental documents. You must attach the death certificate. (See instructions) Authorization to receive confidential tax information under Reg. section 61.54(b)(2)(i); to act as the estate's representative before the IRS; and to make written or oral presentations on behalf of the estate: Name of representative (print or type) State Address (number, street, and room or suite no., city, state, and ZIP code) James Doe, Esq. I declare that I am the attorney/ certified public accountant/ enrolled agent (check the applicable box) for the executor. I am not under suspension or disbarment from practice before the Internal Revenue Service and am qualified to practice in the state shown above. Signature CAF number Date Telephone number 1 Death certificate number and issuing authority (attach a copy of the death certificate to this return). P Commonwealth of Penna. 2 Decedent's business or occupation. If retired, check here and state decedent's former business or occupation. Mime I 3a Marital status of the decedent at time of death: Married Widow/widower Single Legally separated Divorced 3b For all prior marriages, list the name and SSN of the former spouse, the date the marriage ended, and whether the marriage ended by annulment, divorce, or death. Attach additional statements of the same size if necessary. 4a Surviving spouse's name 4b Social security number 4c Amount received (see instructions) 5 PA Buck & Doe, LLC, 15 Main Street Rosemont, PA Department of Health (1) Larry Fensky SSN: Divorced 12/7/1942 (2) John Wayner SSN: Divorced 12/7/1952; (3) Richard Barton SSN: widowed 12/7/1962; (4) Mike Todsky SSN: divorced 12/7/1965 Edward Fleisher Individuals (other than the surviving spouse), trusts, or other estates who receive benefits from the estate (do not include charitable beneficiaries shown in Schedule O) (see instructions). Name of individual, trust, or estate receiving $5, or more Identifying number Relationship to decedent Amount (see instructions) 1 2 Yes No 1,756,341 Bubbles Barton Daughter 34,66 Credit Shelter Trust Applied For Credit Shelter T 1,426,381 All unascertainable beneficiaries and those who receive less than $5, mmmmmmmmmmmmmmmmmmmmmmmmmi Total mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm If you answer "Yes" to any of the following questions, you must attach additional information as described. Yes No Is the estate filing a protective claim for refund? If "Yes," complete and attach two copies of Schedule PC for each claim. 7 Does the gross estate contain any section 244 property (qualified terminable interest property (QTIP) from a prior gift or estate)? 6 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm (see instructions)m mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 8a mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Have federal gift tax returns ever been filed? If "Yes," attach copies of the returns, if available, and furnish the following information: b Period(s) covered c Internal Revenue office(s) where filed See Attached 9a Was there any insurance on the decedent's life that is not included on the return as part of the gross estate?m mmmmmmmmmmmm b Did the decedent own any insurance on the life of another that is not included in the gross estate? See Attached JSA 1R mmmmmmmmmmmmmmmmm 1,46,447 Page 2

37 Estate of: Beth R Tyler Philadelphia, PA Page 2, Part 4 General Information, lines 7b and 7c 37

38 Form 76 (Rev ) Decedent's social security number Estate of: Beth R Tyler Part 4 - General Information (continued) If you answer "Yes" to any of the following questions, you must attach additional information as described. Yes No 1 Did the decedent at the time of death own any property as a joint tenant with right of survivorship in which (a) one or more of the other joint tenants was someone other than the decedent's spouse, and (b) less than the full value of the property is included on the return as part of the gross estate? If "Yes," you must complete and attach Schedule E mmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmm complete and attach Schedule G mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 11a Did the decedent, at the time of death, own any interest in a partnership (for example, a family limited partnership), an unincorporated business, or a limited liability company; or own any stock in an inactive or closely held corporation? b If "Yes," was the value of any interest owned (from above) discounted on this estate tax return? If "Yes," see the instructions on reporting the total accumulated or effective discounts taken on Schedule F or G 12 Did the decedent make any transfer described in sections 235, 236, 237, or 238? (see instructions) If "Yes," you must 13a Were there in existence at the time of the decedent's death any trusts created by the decedent during his or her lifetime? mmmmmmmm b Were there in existence at the time of the decedent's death any trusts not created by the decedent under which the decedent possessed any power, beneficial interest, or trusteeship? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmm c Was the decedent receiving income from a trust created after October 22, 1986, by a parent or grandparent? If "Yes," was there a GST taxable termination (under section 2612) on the death of the decedent? d If there was a GST taxable termination (under section 2612), attach a statement to explain. Provide a copy of the trust or will creating the trust, and give the name, address, and phone number of the current trustee(s). e Did the decedent at any time during his or her lifetime transfer or sell an interest in a partnership, limited liability company, or closely held corporation to a trust described in lines 13a or 13b?m mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," provide the EIN for this transferred/sold item. I 14 Did the decedent ever possess, exercise, or release any general power of appointment? If "Yes," you must complete and attach Schedule Hm mmmmmmmm 15 Did the decedent have an interest in or a signature or other authority over a financial account in a foreign country, such as a bank account, securities account, or other financial account? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 16 Was the decedent, immediately before death, receiving an annuity described in the "General" paragraph of the instructions for Schedule I or a private annuity? If "Yes," you must complete and attach Schedule I mmmmmmmmmmmmmmmmmmmmmmmmmmm 17 Was the decedent ever the beneficiary of a trust for which a deduction was claimed by the estate of a predeceased spouse under section 256(b)(7) and which is not reported on this return? If "Yes," attach an explanation mmmmmmmmmmmmmmmmmmmm Part 5 - Recapitulation. Note. If estimating the value of one or more assets pursuant to the special rule of Reg. section T(a)(7)(ii), enter on both lines 1 and 23 the amount noted in the instructions for the corresponding range of values. (See instructions for details.) mmmmmmmmmmmmmmmmmmmmmmmmmm Item no. Gross estate Alternate value Value at date of death 1 Schedule A - Real Estate 1 2 Schedule B - Stocks and Bonds mmmmmmmmmmmmmmmmmmmmmmm 2 3 Schedule C - Mortgages, Notes, and Cash mmmmmmmmmmmmmmmmmm 3 4 Schedule D - Insurance on the Decedent's Life (attach Form(s) 712) mmmmm 4 5 Schedule E - Jointly Owned Property (attach Form(s) 712 for life insurance) mm 5 6 Schedule F - Other Miscellaneous Property (attach Form(s) 712 for life insurance) 6 7 Schedule G - Transfers During Decedent's Life (att. Form(s) 712 for life insurance) mm 7 8 Schedule H - Powers of Appointment 8 9 Schedule I - Annuities mmmmmmmmmmmmmmmmmmmmmmmmmmm 9 1 Estimated value of assets subject to the special rule of Reg. section T(a)(7)(ii) m 1 11 Total gross estate (add items 1 through 1) mmmmmmmmmmmmmmmmm Schedule U - Qualified Conservation Easement Exclusion mmmmmmmmmm Total gross estate less exclusion (subtract item 12 from item 11). Enter here and on line 1 of Part 2 - Tax Computation mmmmmmmmmmmmmmmmmm 13 Item no. Deductions Amount 14 Schedule J - Funeral Expenses and Expenses Incurred in Administering Property Subject to Claims Schedule K - Debts of the Decedent mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmm Schedule K - Mortgages and Liens mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Total of items 14 through 16 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Allowable amount of deductions from item 17 (see the instructions for item 18 of the Recapitulation) mmmm Schedule L - Net Losses During Administrationmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 19 2 Schedule L - Expenses Incurred in Administering Property Not Subject to Claimsmmmmmmmmmmmmmmm 2 21 Schedule M - Bequests, etc., to Surviving Spousemmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Schedule O - Charitable, Public, and Similar Gifts and Bequests mmmmmmmmmmmmmmmmmmmmmmm Estimated value of deductible assets subject to the special rule of Reg. section T(a)(7)(ii) mmmmmm Tentative total allowable deductions (add items 18 through 23). Enter here and on line 2 of the Tax Computation 24 JSA 2,74,114 1R Page , 71,489 2,1 1,463 1,19,826 13,9 345,445 6, ,27 3,535,925 3,535,925 79,847 8,5 11, ,42 189,42 4,5 11,25 1,756, ,26

39 Form 76 (Rev ) Decedent's social security number Estate of: Beth R Tyler Part 6 - Portability of Deceased Spousal Unused Exclusion (DSUE) Portability Election A decedent with a surviving spouse elects portability of the deceased spousal unused exclusion (DSUE) amount, if any, by completing and timely-filing this return. No further action is required to elect portability of the DSUE amount to allow the surviving spouse to use the decedent's DSUE amount. Section A. Opting Out of Portability The estate of a decedent with a surviving spouse may opt out of electing portability of the DSUE amount. Check here and do no complete Sections B and C of Part 6 only if the estate opts NOT to elect portability of the DSUE amount. Section B. QDOT Yes No Are any assets of the estate being transferred to a qualified domestic trust (QDOT)? mmmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," the DSUE amount portable to a surviving spouse (calculated in Section C, below) is preliminary and shall be redetermined at the time of the final distribution or other taxable event imposing estate tax under section 256A. See instructions for more details. Section C. DSUE Amount Portable to the Surviving Spouse (To be completed by the estate of a decedent making a portability election.) Complete the following calculation to determine the DSUE amount that can be transferred to the surviving spouse. 1 1 Enter amount from line 9c, Part 2 - Tax Computationm mmmmmmmmmmmmmmmmmmmmmmmmmmmm 2 Enter amount from line 7, Part 2 - Tax Computation 2 mmmmmmmmmmmmmmmmmmmmmmmmmmmmm 3 Divide amount on line 2 by 35% (.35). (do not enter less than zero) 3 mmmmmmmmmmmmmmmmmmmmm 4 Add lines 1 and 3 4 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 5 Enter the amount from line 5, Part 2 - Tax Computation 5 mmmmmmmmmmmmmmmmmmmmmmmmmmm 6 Subtract line 5 from line 4 (do not enter less than zero) mmmmmmmmmmmmmmmmmmmmmmmmmmmm 6 7 DSUE amount portable to the surviving spouse (Enter the lesser of line 6 or line 9a, Part 2 - Tax Computation) 7 5,12, 175, 5, 5,62, 2,96,852 2,659,148 2,659,148 Section D. DSUE Amount Received from Predeceased Spouse(s) (To be completed by the estate of a deceased surviving spouse with DSUE amount from predeceased spouse(s)) Provide the following information to determine the DSUE amount received from deceased spouses. A Name of Deceased Spouse (dates of death after December 31, 21, only) B Date of Death (enter as mm/dd/yy) C Portability Election Made? D If "Yes," DSUE Amount Received from Spouse E DSUE Amount Applied by Decedent to Lifetime Gifts F Year of Form 79 Reporting Use of DSUE Amount Listed in col E G Remaining DSUE Amount, if any (subtract col. E from col. D) Yes Part 1 - DSUE RECEIVED FROM LAST DECEASED SPOUSE No Part 2 - DSUE RECEIVED FROM OTHER PREDECEASED SPOUSE(S) AND USED BY DECEDENT Total (for all DSUE amounts from predeceased spouse(s) applied) mmmmmmmmmmm Add the amount from Part 1, column D and the total from Part 2 column E. Enter the result on line 9b, Part 2-Tax Computation mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm I JSA Page 4 1R

40 Estate of: Beth R Tyler Form 76 Page 4, Part 6, Section D, DSUE Amount Received from Predeceased Spouse(s) C E B Portability D DSUE AMount F G A Date Election DSUE Amount Applied to Year of Form Remaining Name of Deceased Spouse of Death Made? Received Lifetime Gifts 79 Reporting DSUE Amount Yes No Part 1 - DSUE Received from Last Deceased Spouse None Part 2 - DSUE Received from Other Predeceased Spouse(s) and Used by Decedent None Total (for all DSUE amounts applied) Add amount from Part 1, Column D and Total of Part 2, Column E 4

41 Form 76 (Rev ) Decedent's social security number Estate of: Beth R Tyler % SCHEDULE A - Real Estate For jointly owned property that must be disclosed on Schedule E, see instructions. Real estate that is part of a sole proprietorship should be shown on Schedule F. Real estate that is included in the gross estate under sections 235, 236, 237, or 238 should be shown on Schedule G. Real estate that is included in the gross estate under section 241 should be shown on Schedule H. If you elect section 232A valuation, you must complete Schedule A and Schedule A-1. Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T (a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entries in the last three columns. Item number Alternate Description Alternate value Value at date of death valuation date 1 1/2 interest in 2544 St. Charles Place, Ocean City, New Jersey Asset held as tenants in common with James Tyler (brother). 65, See attached appraisal 2 Deep Gas rights, Gas leases, as reflected in Memorandum of Assignment by and between the Estate and NatGas Resources dated October 31, , Valuation represents assignment of deep gas rights for 1 acres at $3, per acre. Total from continuation schedules or additional statements attached to this schedulem mmmmm TOTAL. (Also enter on Part 5 - Recapitulation, page 3, at item 1.)m mmmmmmmmmmmmmmmm 68, (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) JSA 1R Schedule A - Page 5

42 Form 76 (Rev ) Decedent's social security number Estate of: Beth R Tyler SCHEDULE B - Stocks and Bonds (For jointly owned property that must be disclosed on Schedule E, see instructions.) Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T(a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entries in the last four columns. Item number Description, including face amount of bonds or number of shares and par value for identification. Give CUSIP number. If trust, partnership, or closely held entity, give EIN. CUSIP number or EIN, where applicable Unit value Alternate valuation date Alternate value Value at date of death 1 5, Par Allegheny Cnty PA G.O. Bds Mat: 11/1/ % EIN: v ,1 Interest accrued to 1/5/ Shares American Greeting Corp Class A CUSIP: , Par Blue Ridge PA Sch Dist G.O. Sch Di Mat: 6/1/ % EIN: 95895em ,53 Interest accrued to 1/5/ , Par Montgomery County PA G.O. Bds Mat: 12/1/213 2% EIN: ve ,433 Interest accrued to 1/5/212 1,54 5 2, Units Vanguard Total Bond Market CUSIP: ,253 ROSEMONT TRUST COMPANY, BROKERAGE ACCOUNT RTC-1455 Assets listed below 6 2,5 Shares Sysco Corp. CUSIP: ,338 Total from continuation schedules (or additional statements) attached to this schedule mmmmm TOTAL. (Also enter on Part 5 - Recapitulation, page 3, at item 2.) mmmmmmmmmmmmmmmmm 71,489 (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) Schedule B - Page 1 JSA 1R ,

43 Form 76 (Rev ) (Make copies of this schedule before completing it if you will need more than one schedule.) Decedent's social security number Estate of: Beth R Tyler Item number CONTINUATION SCHEDULE Continuation of Schedule B (Page 2) Description. For securities, give CUSIP number. If trust, partnership, or closely held entity, give EIN. (Enter letter of schedule you are continuing.) Unit value (Sch. B, E, or G only) Alternate valuation date Alternate value Value at date of death or amount deductible 7 2,5 Shares Yum Brands Inc Common New York Stock Exchange CUSIP: , JSA 1R TOTAL. (Carry forward to main schedule.)m mmmmmmmmmmmmmmmmmmmmmmmmmmmmm , Continuation Schedule - Page 31

44 Form 76 (Rev ) Decedent's social security number Estate of: Beth R Tyler SCHEDULE C - Mortgages, Notes, and Cash (For jointly owned property that must be disclosed on Schedule E, see instructions.) Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T(a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entries in the last three columns. Item number Description Alternate valuation date Alternate value Value at date of death 1 Friendly Bank, Checking Account ,45 Interest accrued to 1/5/ Friendly Bank, Savings Account ,53 Interest accrued to 1/5/212 1 mmmmm mmmmmmmmmmmmmmmmm Total from continuation schedules (or additional statements) attached to this schedule TOTAL. (Also enter on Part 5 - Recapitulation, page 3, at item 3.) 2,1 (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) JSA Schedule C - Page 11 1R

45 Form 76 (Rev ) Decedent's social security number Estate of: Beth R Tyler SCHEDULE D - Insurance on the Decedent's Life You must list all policies on the life of the decedent and attach a Form 712 for each policy. Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T(a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entries in the last three columns. Item number Description Alternate valuation date Alternate value Value at date of death 1 FOR INFORMATION ONLY: Prudential Life Insurance Whole life Policy paid $549, of proceeds at decedent's death. Policy was owned by Tyler Irrevocable Life Insurance Trust dated 1/24/1993 (listed on Schedule G). Proceeds not includible in Decedent's estate as Decedent had no incidents of ownership in the policy. 2 Veterans Life Insurance Policy V Beneficiary: Surviving spouse 1,463 mmmmm mmmmmmmmmmmmmmmmm Total from continuation schedules (or additional statements) attached to this schedule TOTAL. (Also enter on Part 5 - Recapitulation, page 3, at item 4.) 1,463 (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) JSA Schedule D - Page 12 1R

46 Form 76 (Rev ) Decedent's social security number Estate of: Beth R Tyler SCHEDULE E - Jointly Owned Property (If you elect section 232A valuation, you must complete Schedule E and Schedule A-1.) PART 1. Qualified Joint Interests - Interests Held by the Decedent and His or Her Spouse as the Only Joint Tenants (Section 24(b)(2)) Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T(a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entries in the last three columns. Item number Description. For securities, give CUSIP number. If trust, partnership, or closely held entity, give EIN. Alternate valuation date Alternate value Value at date of death CUSIP number or EIN, where applicable 1 2,4 Shares Bank of America Corp. Unit Value: CUSIP: ,5 1a 1b Total from continuation schedules (or additional statements) attached to this schedule mmmmm Totals mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Amounts included in gross estate (one-half of line 1a)m mmmmmmmmmmmmmmmmmmmm PART 2. 2a All Other Joint Interests State the name and address of each surviving co-tenant. If there are more than three surviving co-tenants, list the additional cotenants on an attached statement. 1a 1b 636, ,13 335,57 A. B. Name Address (number and street, city, state, and ZIP code) Edward Fleisher 23 Lowry's Lane, Rosemont, PA 191 Bubbles Barton 14 Elm Street, Rosemont, PA 191 C. Item number Enter letter for co-tenant Description (including alternate valuation date if any). For securities, give CUSIP number. If trust, partnership, or closely held entity, give EIN CUSIP number or EIN, where applicable Percentage includible Includible alternate value Includible value at date of death 1 B Friendly Bank, Checking Account ,319 Total from continuation schedules (or additional statements) attached to this schedule mmmmm 75, 2b Total other joint interests mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 2b 774,319 3 Total includible joint interests (add lines 1b and 2b). Also enter on Part 5 - Recapitulation, page 3, at item 5mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 3 1,19,826 (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) JSA Schedule E - Page 13 1R

47 Estate of: Beth R Tyler Schedule E Part 1 (Page 2) Item Alt. Val Alternate Value at No. Description Unit Value Date Value Date of Death House and lot located at 26 Garrett Avenue, Rosemont, Pennsylvania , See attached appraisal 3 2,3 Shares Johnson & Johnson CUSIP: , Shares Kraft Foods Inc. A CUSIP: 575N ,91 Dividend accrued on 1/5/ , Shares Krispy Kreme Doughnuts Inc Common New York Stock Exchange CUSIP: ,58 6 Personal property located at 23 Lowry's Lane, Rosemont, Pennsylvania 191 9,3 See attached appraisal 7 1 Shares Wells Fargo CUSIP: ,195 Total (Carry forward to main schedule) ,513

48 Estate of: Beth R Tyler Schedule E Part 2 (Page 2) Item Unit Percent Alternate Value at No. Ltr Description Value Includible Value Date of Death A House and lot located at 23 Lowry's Lane Street, Rosemont, Pennsylvania 191 Property owned as tenants by entireties by decedent and spouse. Property was purchased in 1972 and all consideration was paid by decedent. Under Gallenstein vs. U.S. 975 F2d 286, the entire property is included in decedent's estate , appraisal attached Total (Carry forward to main schedule) 48 75,

49 Form 76 (Rev ) Decedent's social security number Estate of: Beth R Tyler SCHEDULE F - Other Miscellaneous Property Not Reportable Under Any Other Schedule (For jointly owned property that must be disclosed on Schedule E, see instructions.) (If you elect section 232A valuation, you must complete Schedule F and Schedule A-1.) Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T(a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entries in the last three columns. 1 Did the decedent own any works of art, items, or any collections whose artistic or collectible value at date of death exceeded $3,? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," submit full details on this schedule and attach appraisals. 2 Has the decedent's estate, spouse, or any other person received (or will receive) any bonus or award as a result of the decedent's employment or death?m mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," submit full details on this schedule. 3 Did the decedent at the time of death have, or have access to, a safe deposit box? mmmmmmmmmmmmmmmmmmmmm If "Yes," state location, and if held jointly by decedent and another, state name and relationship of joint depositor. See attached Yes No If any of the contents of the safe deposit box are omitted from the schedules in this return, explain fully why omitted. See attached Item number Description. For securities, give CUSIP number. If trust, partnership, or closely held entity, give EIN CUSIP number or EIN, where applicable Alternate valuation date Alternate value Value at date of death 1 24 Mini Cooper 4,5 2 5% limited partnership interest in Tyler Family LP 9,4 See attached valuation mmmm mmmmmmmmmmmmmmmm Total from continuation schedules (or additional statements) attached to this schedule TOTAL. (Also enter on Part 5 - Recapitulation, page 3, at item 6.) 13,9 (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) JSA 1R Schedule F - Page 14 49

50 Estate of: Beth R Tyler Schedule F - Question 3 (Page 1) Location and if held in joint names of decedent and another, state name and relationship of joint depositor. Friendly Bank, Bryn Mawr, PA Box #151 Joint Depositor: Edward Fleisher (surviving spouse) If any of the contents of the safe deposit box are omitted from the schedules in this return, explain fully why omitted. none omitted 5

51 Form 76 (Rev ) Decedent's social security number Estate of: Beth R Tyler SCHEDULE G - Transfers During Decedent's Life (If you elect section 232A valuation, you must complete Schedule G and Schedule A-1.) Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T(a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entries in the last three columns. Item number Description. For securities, give CUSIP number. If trust, partnership, or closely held entity, give EIN Alternate valuation date Alternate value Value at date of death A. Gift tax paid or payable by the decedent or the estate for all gifts made by the decedent or his or her spouse within 3 years before the decedent's death (section 235(b))m mmmmmmmmmmmmmmmmmmmm B. Transfers includible under sections 235(a), 236, 237, or 238: 1 25 Par $25 US Savings Bond, Series EE dated 9/8/1973 Payable on death to: Bubbles Barton (daughter) Unit Value: Total from continuation schedules (or additional statements) attached to this schedule mmmmm TOTAL. (Also enter on Part 5 - Recapitulation, page 3, at item 7.) mmmmmmmmmmmmmmmmm SCHEDULE H - Powers of Appointment (Include "5 and 5 lapsing" powers (section 241(b)(2)) held by the decedent.) (If you elect section 232A valuation, you must complete Schedule H and Schedule A-1.) Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T(a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entries in the last three columns. Item number Description Alternate valuation date Alternate value 345,98 345,445 Value at date of death 1 Decedent had the right to withdraw the greater of 5% or $5, from the Geoffrey Tyler Trust dated 1/23/ ,432 Total from continuation schedules (or additional statements) attached to this schedule mmmmmmm TOTAL. (Also enter on Part 5 - Recapitulation, page 3, at item 8.)m mmmmmmmmmmmmmmmmmm 6,432 (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) JSA 1R Schedules G and H - Page 15 51

52 Form 76 (Rev ) (Make copies of this schedule before completing it if you will need more than one schedule.) Decedent's social security number Estate of: Beth R Tyler Item number CONTINUATION SCHEDULE Continuation of Schedule G (Page 2) Description. For securities, give CUSIP number. If trust, partnership, or closely held entity, give EIN. (Enter letter of schedule you are continuing.) Unit value (Sch. B, E, or G only) Alternate valuation date Alternate value Value at date of death or amount deductible 2 FOR INFORMATION ONLY: Decedent executed the Tyler Irrevocable Life Insurance Trust dated 1/24/1993. All gifts to the trust were duly reported on gift tax returns filed by the Decedent. The trust is not includible in Decedent's estate. DECEDENT EECUTED THE BETH TYLER REVOCABLE TRUST DATED 6/1/24, as amended twenty-three times. Assets listed below. 3 2 Shares Heinz H J Co Common New York Stock Exchange CUSIP: ,818 Dividend accrued on 1/5/ , Shares McDonalds Corp. CUSIP: ,42 5 1, Shares erox Corp. CUSIP: ,42 Dividend accrued on 1/5/ DECEDENT EECUTED THE TYLER FAMILY CHARITABLE REMAINDER UNITRUST DATED 6/14/21. Decedent received the annuity payments for Decedent's lifetime. Trust continues for the benefit of Decedent's suriviving spouse. At surviving spouse's death, trust terminates to Germantown SPCA. Assets listed below. 6 2 Shares General Mills, Inc. CUSIP: ,257 JSA 1R TOTAL. (Carry forward to main schedule.)m mmmmmmmmmmmmmmmmmmmmmmmmmmmmm ,48 Continuation Schedule - Page 31

53 Form 76 (Rev ) (Make copies of this schedule before completing it if you will need more than one schedule.) Decedent's social security number Estate of: Beth R Tyler CONTINUATION SCHEDULE Item number 7 1, Shares Pfizer, Inc. Continuation of Schedule G (Page 3) Description. For securities, give CUSIP number. If trust, partnership, or closely held entity, give EIN. (Enter letter of schedule you are continuing.) Unit value (Sch. B, E, or G only) Alternate valuation date Alternate value Value at date of death or amount deductible CUSIP: ,5 JSA 1R TOTAL. (Carry forward to main schedule.)m mmmmmmmmmmmmmmmmmmmmmmmmmmmmm 53 18,5 Continuation Schedule - Page 31

54 Form 76 (Rev ) Decedent's social security number Estate of: Beth R Tyler SCHEDULE I - Annuities Note. Generally, no exclusion is allowed for the estates of decedents dying after December 31, 1984 (see instructions). Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T(a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entries in the last three columns. A Are you excluding from the decedent's gross estate the value of a lump-sum distribution described in section Yes No 239(f)(2) (as in effect before its repeal by the Deficit Reduction Act of 1984)?m mmmmmmmmmmmmmmmmmmmmmmm If "Yes," you must attach the information required by the instructions. Item Description. Alternate valuation Includible alternate Includible value at number Show the entire value of the annuity before any exclusions date value date of death 1 FOR INFORMATION ONLY: Decedent received monthly pension payments from Street Performers Retirement Program. These payments terminated at death with no further value. 2 Vanguard Individual Retirement Account V-2563 Beneficiary: Surviving Spouse 645,331 Interest accrued to 1/5/212 2,939 Total from continuation schedules (or additional statements) attached to this schedule mmmmm TOTAL. (Also enter on Part 5 - Recapitulation, page 3, at item 9.) mmmmmmmmmmmmmmmmm 648,27 (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) JSA 1R Schedule I - Page 16 54

55 Form 76 (Rev ) Decedent's social security number Estate of: Beth R Tyler SCHEDULE J I- Funeral Expenses and Expenses Incurred in Administering Property Subject to Claims Use Schedule PC to make a protective claim for refund due to an expense not currently deductible. For such a claim, report the expense on Schedule J but without a value in the last column. Note. Do not list expenses of administering property not subject to claims on this schedule. To report those expenses, see instructions. If executors' commissions, attorney fees, etc., are claimed and allowed as a deduction for estate tax purposes, they are not allowable as a deduction in computing the taxable income of the estate for federal income tax purposes. They are allowable as an income tax deduction on Form 141, U.S. Income Tax Return for Estates and Trusts, if a waiver is filed to forgo the deduction on Form 76 (see Instructions for Form 141). Are you aware of any actual or potential reimbursement to the estate of any expense claimed as a deduction on this Yes No schedule? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," attach a statement describing the expense(s) subject to potential reimbursement. (see instructions) Item Description Expense amount Total amount number A. Funeral expenses: 1 Meadowville - Funeral reception 1,134 2 Robertsons Florist 766 Total from continuation schedules Total funeral expenses mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm B. Administration expenses: 1 Executors' commissions - amount estimated/agreed upon/paid. (Strike out the words that do not apply.) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 2 Attorney fees - amount estimated/agreed upon/paid. (Strike out the words that do not apply.) mmmmm 3 Accountant fees - amount estimated/agreed upon/paid. (Strike out the words that do not apply.)m mmm I 6,9 7,99 6, 1, 3,5 Expense amount 4 Miscellaneous expenses: 1 Comcast Department of Health Vital Statistics - Death Certificates 9 3 James Tyler - Clean out of 2544 St. Charles Place, Ocean City, New Jersey 25, 4 Expense of sale of 2544 St. Charles Place, Ocean City, NJ 23,45 5 Jim's Appraisal Services - Real estate appraisal-2544 St. Charles Place, Ocean City, New Jersey 5 6 New Jersey Power and Light 45 7 Register of Wills - Probate fees 2,4 8 Register of Wills - Short certificates 12 Total miscellaneous expenses from continuation schedules (or additional statements) attached to this schedule mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Total miscellaneous expenses mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmi mmmmmmmmmmmmmmmmmmmmmmmmi TOTAL. (Also enter on Part 5 Recapitulation, page 3, at item 14.) 79,847 (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) Schedule J - Page 17 JSA 1R ,357

56 Estate of: Beth R Tyler Schedule J Part A (Page 2) Item No. Description Amount Stretch Funeral Home 6,9 Total (Carry forward to main schedule) 56 6,9

57 Estate of: Beth R Tyler Schedule J Part B (Page 2) Item No. Description Amount Ted's Auction House - Personal property appraisal 35 1 William J. Mansfield, Inc. - Estate advertisement 259 Total (Carry forward to main schedule) 57 69

58 Form 76 (Rev ) Decedent's social security number Estate of: Beth R Tyler SCHEDULE K - Debts of the Decedent, and Mortgages and Liens I Use Schedule PC to make a protective claim for refund due to a claim not currently deducible. For such a claim, report the expense on Schedule K but without a value in the last column. Yes No Are you aware of any actual or potential reimbursement to the estate for any debt of the decedent, mortgage, or lien claimed as a deduction on this schedule? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," attach a statement describing the items subject to potential reimbursement. (see instructions) Are any of the items on this schedule deductible under Reg. section (b) and Reg. section (c)? mmmm If "Yes," attach a statement indicating the applicable provision and documenting the value of the claim. Item Debts of the Decedent - Creditor and nature of debt, and Amount number allowable death taxes 1 American Express 2,434 2 Bryn Mawr Hospital 63 3 Buck & Doe, LLC - Lifetime legal expenses 2,4 4 Church of the Redeemer, Bryn Mawr Pennsylvania - Balance of 211 charitable pledge 2,5 5 Comcast 15 6 John Smith, M.D PA Department of Revenue Form PA TMobile 55 Total from continuation schedules (or additional statements) attached to this schedule mmmmmmmmmmmmmm TOTAL. (Also enter on Part 5 - Recapitulation, page 3, at item 15.)m mmmmmmmmmmmmmmmmmmmmmmmmm Item number Mortgages and Liens - Description Amount 8,5 1 1,5 Par Mortgage balance on 1/2 interest in 2544 St. Charles Place, Ocean City, New Jersey 1,5 Interest accrued to 1/5/ mmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmm Total from continuation schedules (or additional statements) attached to this schedule TOTAL. (Also enter on Part 5 - Recapitulation, page 3, at item 16.) 11,145 (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) JSA Schedule K - Page 18 1R

59 Form 76 (Rev ) Decedent's social security number Estate of: Beth R Tyler SCHEDULE L - Net Losses During Administration and Expenses Incurred in Administering Property Not Subject to Claims Item number IUse Schedule PC to make a protective claim for refund due to an expense not currently deductible. For such expenses, report the expense on Schedule L but without a value in the last column. Net losses during administration (Note. Do not deduct losses claimed on a federal income tax return.) 1 Uninsured loss of 24 Mini Cooper - Automobile was destroyed by winter storm. 4,5 Amount Total from continuation schedules (or additional statements) attached to this schedule TOTAL. (Also enter on Part 5 - Recapitulation, page 3, at item 19.) Item number Expenses incurred in administering property not subject to claims. (Indicate whether estimated, agreed upon, or paid.) mmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmm Amount 4,5 1 Buck & Doe, LLC - Attorney's fees to settle Decedent's Revocable Trust 5, 2 Rosemont Trust Company - Trustee fees to settle and terminate Revocable Trust 6, 3 US Treasury Direct - US Postal Fees to submit forms for reregistration and direct deposit of US Savings Bond to son 25 mmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmm Total from continuation schedules (or additional statements) attached to this schedule TOTAL. (Also enter on Part 5 - Recapitulation, page 3, at item 2.) 11,25 (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) JSA 1R Schedule L - Page 19 59

60 Form 76 (Rev ) Estate of: Beth R Tyler SCHEDULE M - Bequests, etc., to Surviving Spouse Decedent's social security number Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T (a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entry in the last column. Yes No 1 Did any property pass to the surviving spouse as a result of a qualified disclaimer? mmmmmmmmmmmmmmmmmmm 1 If "Yes," attach a copy of the written disclaimer required by section 2518(b). 2a In what country was the surviving spouse born? USA b What is the surviving spouse's date of birth? 3/14/1941 c Is the surviving spouse a U.S. citizen? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 2c d If the surviving spouse is a naturalized citizen, when did the surviving spouse acquire citizenship? e If the surviving spouse is not a U.S. citizen, of what country is the surviving spouse a citizen? 3 Election Out of QTIP Treatment of Annuities. Do you elect under section 256(b)(7)(C)(ii) not to treat as qualified terminable interest property any joint and survivor annuities that are included in the gross estate and would otherwise be treated as qualified terminable interest property under section 256(b)(7)(C)? (see instructions) mmmm Item Description of property interests passing to surviving spouse. number For securities, give CUSIP number. If trust, partnership, or closely held entity, give EIN QTIP property: None Amount 2A 2B 2C 2D All other property: Annuity Interest in Tyler Family Charitable Remainder Unitrust dated 6/4/21 12,11 5% of Bank of America Corp. CUSIP: ,25 5% of House and lot located at 26 Garrett Avenue, Rosemont, Pennsylvania , 5% of Johnson & Johnson CUSIP: ,732 Total from continuation schedules (or additional statements) attached to this schedule mmmmmmmmmmmmmm 4 Total amount of property interests listed on Schedule Mmmmmmmmmmmmmmmmmmmmmmmmmmmm 4 5a Federal estate taxes payable out of property interests listed on Schedule M mmmmmm 5a b Other death taxes payable out of property interests listed on Schedule Mmmmmmmmm 5b c Federal and state GST taxes payable out of property interests listed on Schedule M 5c d Add items 5a, 5b, and 5cm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 6 Net amount of property interests listed on Schedule M (subtract 5d from 4). Also enter on Part 5 - Recapitulation, page 3, at item 21 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 6 1,756,341 (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) JSA Schedule M - Page 2 1R d 1,429,258 1,756,341

61 Estate of: Beth R Tyler Schedule M All Other Property (Page 2) Item No. Description Amount E 5% of Kraft Foods Inc. A CUSIP: 575N14 3,987 2F 2G 5% of Krispy Kreme Doughnuts Inc Common New York Stock Exchange CUSIP: ,29 5% of Personal property located at 23 Lowry's Lane, Rosemont, Pennsylvania 191 4,65 2H 1% of Vanguard Individual Retirement Account V-2563 Beneficiary: Surviving Spouse 648,27 2I 1% of Veterans Life Insurance Policy V Beneficiary: Surviving spouse 1,463 2J 2K 5% of Wells Fargo CUSIP: ,598 1% of House and lot located at 23 Lowry's Lane Street, Rosemont, Pennsylvania 191 Property owned as tenants by entireties by decedent and spouse. Property was purchased in 1972 and all consideration was paid by decedent. Under Gallenstein vs. U.S. 975 F2d 286, the entire property is included in decedent's estate. 75, Total (Carry forward to main schedule) 61 1,429,258

62 Form 76 (Rev ) Decedent's social security number Estate of: Beth R Tyler SCHEDULE O - Charitable, Public, and Similar Gifts and Bequests Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T (a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entry in the last column. Yes No 1a If the transfer was made by will, has any action been instituted to contest or have interpreted any of its provisions b affecting the charitable deductions claimed in this schedule? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," full details must be submitted with this schedule. According to the information and belief of the person or persons filing this return, is any such action planned? mmmmm If "Yes," full details must be submitted with this schedule. 2 Did any property pass to charity as the result of a qualified disclaimer? mmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," attach a copy of the written disclaimer required by section 2518(b). Item number Name and address of beneficiary Character of institution 1 Remainder interest in Tyler Family Charitable Remainder Unitrust dated 6/14/21 Cruelty to Animal 13,26 2 Specific Bequest to Germantown Academy Educational 1, Amount Total from continuation schedules (or additional statements) attached to this schedule mmmmmmmmmmmmmmmmm 3 Total mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 3 4a Federal estate tax payable out of property interests listed above mmmmmmmmmm 4a b Other death taxes payable out of property interests listed above mmmmmmmmmm 4b c Federal and state GST taxes payable out of property interests listed above mmmmm 4c d Add items 4a, 4b, and 4c mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 4d 5 Net value of property interests listed above (subtract 4d from 3). Also enter on Part 5 - Recapitulation, page 3, at item 22 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 5 113,26 113,26 (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) Schedule O - Page 21 JSA 1R

63 Form 76 (Rev ) SCHEDULE R - Generation-Skipping Transfer Tax Note. To avoid application of the deemed allocation rules, Form 76 and Schedule R should be filed to allocate the GST exemption to trusts that may later have taxable terminations or distributions under section 2612 even if the form is not required to be filed to report estate or GST tax. The GST tax is imposed on taxable transfers of interests in property located outside the United States as well as property located inside the United States. (see instructions) Part 1. GST Exemption Reconciliation (Section 2631) and Special QTIP Election (Section 2652(a)(3)) You no longer need to check a box to make a section 2652(a)(3) (special QTIP) election. If you list qualifying property in Part 1, line 9 below, you will be considered to have made this election. See instructions for details. mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmm 6 Total GST exemption allocated on line 4 of Schedule(s) R-1 mmmmmmmmmmmmmmmmmmmmmm 7 Total GST exemption allocated to inter vivos transfers and direct skips (add lines 2-6) mmmmmmmm 1 Maximum allowable GST exemption 1 2 Total GST exemption allocated by the decedent against decedent's lifetime transfers 2 3 Total GST exemption allocated by the executor, using Form 79, against decedent's lifetime transfers 3 4 GST exemption allocated on line 6 of Schedule R, Part GST exemption allocated on line 6 of Schedule R, Part GST exemption available to allocate to trusts and section 232A interests (subtract line 7 from line 1) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 8 9 Allocation of GST exemption to trusts (as defined for GST tax purposes): 6 7 5,12, 5,12, A B C D E Name of trust Trust's EIN (if any) GST exemption allocated on lines 2-6, above (see instructions) Additional GST exemption allocated (see instructions) Trust's inclusion ratio (optional - see instructions) Credit Shelter Trust Applied For 1,426,381. 9D Total. May not exceed line 8, above mmmmmmmmmmmmmmmmm 9D 1,426,381 1 GST exemption available to allocate to section 232A interests received by individual beneficiaries (subtract line 9D from line 8). You must attach special-use allocation statement (see instructions) m 1 Schedule R - Page 23 JSA 1R

64 Estate of: Beth R Tyler Worksheet TG - Taxable Gifts Reconciliation Total taxable gifts made before 1977 Line 4 - Taxable gifts made after 1976 Calendar Total Taxable amount Amount qualifying Gift tax Gift tax year or taxable gifts included in as special paid by paid by quarter for period gross estate treatment gifts decedent spouse (a) (b) (c) (d) (e) (f) ,5, Totals 1,5, 1. Taxable gifts made after 1976 (from column b) 1,5, 2. Taxable gifts made after 1976 included in gross estate (from column c) 3. Taxable gifts made after 1976 that qualify for "special treatment" (from column d) 4. Add lines 2 and 3 5. Adjusted taxable gifts 1,5, 64

65 Estate of: Beth R Tyler Worksheet TG - Taxable Gifts Reconciliation Line 7 - Gift tax on gifts made after 1976 (a) (b) (c) (d) (e) (f) (g) (h) Cumulative DSUE from Predeceased Cumulative Tax Based Tax on Spouse(s) Taxable Taxable Taxable Gifts on 212 Cumulative Tax on Gifts Applied to Gifts for Gifts for Including Rates for Gifts Including for Current Current & Period Current Period Prior Periods Current Period Prior Gifts Current Period Period Prior Gifts Pre ,5, 1,5, 55,8 55,8 (i) (j) (k) (l) (m) (n) (o) Basic Maximum Applicable Exclusion Applicable Credit Available Tax Amount Credit based Amount Used Credit Payable for Current on amount in Prior in Current Credit for Current Period Total in Column J Periods Period Allowable Period Pre ,, 1,, 33,8 33,8 33,8 175, 1. Total gift taxes payable on gifts made after 1976 (add amounts in column (o)) 175, 2. Gift tax paid by the decedent on gifts that qualify for "special treatment" (from Line 4 worksheet, column e) 3. Subtract line 2 from line 1 175, 4. Gift tax paid by the decedent's spouse on split gifts (from Line 4 worksheet, column f) 5. Add lines 3 and 4 175, 65

66 Estate of Beth Tyler SSN: Date of Death: 1/5/212 Federal Estate Tax Return Calculation of Residue to Credit Shelter Trust Gross Estate 3,535,925 Less Specific Bequest to Germantown Academy (1,) Joint Property to daughter (24,319) EE Bond to daughter (347) 5% FLP Interest to daughter (9,4) Life Insurance to Wife (1,463) House to Wife, Schedule E Part 2 (75,) Joint Property to Wife (335,57) Life Interest in CRUT to Wife (12,11) Annuities to wife (648,27) Remainder Interest in CRUT to Germantown SPCA (13,26) Schedule J (79,847) Schedule K (19,195) Schedule L (15,525) PA Inheritance Tax (actually paid) (1,364) Residue to Credit Shelter Trust 1,426,381 PA Inheritance Tax 4.5% To daughter: $9 taxable gift within one year $9, 45 1/2 of Joint Account with daughter $12, $25 US Savings Bond, Series EE $ % limited Partnership Interest $9,4 423 $3,97 1,391 Calculation of State Death Tax Deduction PA Inheritance Tax - Total 1,391 Less tax on gifts within one year of death (not (45) included in Federal Gross Estate) Less PA Discount allowed on $5 discount payment (26) made within 3 months of death State Death Tax Deduction 959 5/14/2139:1 AM 66

67 Form Department of the Treasury Internal Revenue Service Part 1 - General Information Attach check or money order here. LHA Information about Form 79 and its separate instructions is at (For gifts made during calendar year 212) See instructions. Have you applied a DSUE amount received from a predeceased spouse to a gift or gifts reported on this or a previous Form 79? If "Yes," complete Schedule C OMB No Donor s first name and middle initial 2 Donor s last name 3 Donor s social security number EDWARD FLEISHER Address (number, street, and apartment number) 5 Legal residence (domicile) 23 LOWRY S LANE DELAWARE COUNTY-PA 6 City, state, and ZIP or postal code 7 Citizenship (see instructions) ROSEMONT, PA 191 UNITED STATES a Have you (the donor) previously filed a Form 79 (or 79-A) for any other year? If "No," skip line 11b~~~~~~~~~~~~~~~~~~~~ b Has your address changed since you last filed Form 79 (or 79-A)? 12 Gifts by husband or wife to third parties. Do you consent to have the gifts (including generation-skipping transfers) made by you and by your following information must be furnished and your spouse must sign the consent shown below. If the answer is "No," skip lines ) 18 Consent of Spouse. I consent to have the gifts (and generation-skipping transfers) made by me and by my spouse to third parties during the calendar year considered as made one-half by each of us. We are both aware of the joint and several liability for tax created by the execution of this consent. Consenting spouse s signature Date 19 Part 2 - Tax Computation If the donor died during the year, check here and enter date of death,. If you extended the time to file this Form 79, check here Enter the total number of donees listed on Schedule A. Count each person only once. 1 spouse to third parties during the calendar year considered as made one-half by each of you? (see instructions.) (If the answer is "Yes," the 13 Name of consenting spouse 14 SSN Were you married to one another during the entire calendar year? (see instructions) If 15 is "No," check whether married divorced or widowed/deceased, and give date Will a gift tax return for this year be filed by your spouse? (If "Yes," mail both returns in the same envelope.) 1 Enter the amount from Schedule A, Part 4, line 11 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 1 2 Enter the amount from Schedule B, line 3 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 2 3 Total taxable gifts. Add lines 1 and 2 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 3 4 Tax computed on amount on line 3 (see Table for Computing Gift Tax in instructions) ~~~~~~~~~~~~ 4 5 Tax computed on amount on line 2 (see Table for Computing Gift Tax in instructions) ~~~~~~~~~~~~ Balance. Subtract line 1 from line 9. Do not enter less than zero ~~~~~~~~~~~~~~~~~~~~~~~ Applicable credit. Enter the smaller of line 6 or line 11 ~~~~~~~~~~~~~~~~~~~~~~~~~~~ Credit for foreign gift taxes (see instructions) ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Total credits. Add lines 12 and 13 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Balance. Subtract line 14 from line 6. Do not enter less than zero ~~~~~~~~~~~~~~~~~~~~~~~ Generation-skipping transfer taxes (from Schedule D, Part 3, col. H, Total) ~~~~~~~~~~~~~~~~~~~ Total tax. Add lines 15 and 16 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Gift and generation-skipping transfer taxes prepaid with extension of time to file ~~~~~~~~~~~~~~~~ Sign Here 79 Paid Preparer Use Only Balance. Subtract line 5 from line 4 Applicable credit amount. If donor has DSUE amount from predeceased spouse(s), enter amount from Schedule C, line 5; otherwise, see instructions ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Enter the applicable credit against tax allowable for all prior periods (from Sch. B, line 1, col. C) Balance. Subtract line 8 from line 7. Do not enter less than zero If line 18 is less than line 17, enter balance due (see instructions) ~~~~~~~~~~~~~~~~~~~~~~ 19 If line 18 is greater than line 17, enter amount to be refunded 2 Under penalties of perjury, I declare that I have examined this return, including any accompanying schedules and statements, and to the best of my knowledge and belief, it is true, correct, and complete. Declaration of preparer (other than donor) is based on all information of which preparer has any knowledge. May the IRS discuss this return with the preparer shown below (see instructions)? Yes No = Signature of donor Date Date Print/Type preparer s name Preparer s signature Check if PTIN self-employed Firm s name Firm s EIN Firm s address United States Gift (and Generation-Skipping Transfer) Tax Return ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ For Disclosure, Privacy Act, and Paperwork Reduction Act Notice, see the instructions for this form. ~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~~~~ Enter 2% (.2) of the amount allowed as a specific exemption for gifts made after September 8, 1976, and before January 1, 1977 (see instructions) ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Phone no. 212 Yes No 2,,.! 79 2,,. 68,8. 68,8. 2,472,8. 2,472,8. 2,472,8. 68,8. 68,8.... Form (212) FLEISHER-EDW FLEISHER, EDWARD FLEISH1

68 Form 79 (212) EDWARD FLEISHER Page 2 SCHEDULE A Computation of Taxable Gifts (Including transfers in trust) (see instructions) A Does the value of any item listed on Schedule A reflect any valuation discount? If "Yes," attach explanation Yes No B Check here if you elect under section 529(c)(2)(B) to treat any transfers made this year to a qualified tuition program as made ratably over a 5-year period beginning this year. See instructions. Attach explanation. Part 1 - Gifts Subject Only to Gift Tax. Gifts less political organization, medical, and educational exclusions. (see instructions) A B C D E F G H Donee s name and address Relationship to donor (if any) Donor s adjusted Date Value at For split gifts, Description of gift basis of gift of gift date of gift enter 1/2 of If the gift was of securities, give CUSIP no. If closely held entity, give EIN column F Item number Net transfer (subtract col. G from col. F) 1 BUBBLES BARTON DAUGHTER CASH 2,13,. 6/14/12 2,13,. 2,13,. Gifts made by spouse - complete only if you are splitting gifts with your spouse and he/she also made gifts. Total of Part 1. Add amounts from Part 1, column H J2,13,. Part 2 - Direct Skips. Gifts that are direct skips and are subject to both gift tax and generation-skipping transfer tax. You must list the gifts in chronological order. A B C D E F G H Donee s name and address Relationship to donor (if any) 2632(b) Donor s adjusted Date Value at For split gifts, Description of gift election basis of gift of gift date of gift enter 1/2 of If the gift was of securities, give CUSIP no. If closely held entity, give EIN out column F Item number Net transfer (subtract col. G from col. F) Gifts made by spouse - complete only if you are splitting gifts with your spouse and he/she also made gifts. Total of Part 2. Add amounts from Part 2, column H J Part 3 - Indirect Skips. Gifts to trusts that are currently subject to gift tax and may later be subject to generation-skipping transfer tax. You must list these gifts in chronological order. A B C D E F G H Donee s name and address Relationship to donor (if any) 2632(c) Donor s adjusted Date Value at For split gifts, Description of gift election basis of gift of gift date of gift enter 1/2 of If the gift was of securities, give CUSIP no. If closely held entity, give EIN column F Item number Net transfer (subtract col. G from col. F) Gifts made by spouse - complete only if you are splitting gifts with your spouse and he/she also made gifts. Total of Part 3. Add amounts from Part 3, column H J (If more space is needed, attach additional statements.) Form (212)

69 Form 79 (212) EDWARD FLEISHER SCHEDULE A, PART I CONTINUATION SHEET Part 1 - Gifts Subject Only to Gift Tax. Gifts less political organization, medical, and educational exclusions. (see instructions) A B C D E F G H Donee s name and address Donor s adjusted Date Value at For split gifts, Relationship to donor (if any) basis of gift of gift date of gift enter 1/2 of Description of gift column F If the gift was of securities, give CUSIP no. If closely held entity, give EIN Item number Net transfer (subtract col. G from col. F) Total of column H Form (212) 69 J 79

70 Form 79 (212) Part 4 - Taxable Gift Reconciliation Deductions (see instructions) Total value of gifts of donor. Add totals from column H of Parts 1, 2, and 3 ~~~~~~~~~~~~~~~~~~~~~~~ Total annual exclusions for gifts listed on line 1 (see instructions) ~~~~~~~~~~~~~~~~~~~~~~~~~~~ Total included amount of gifts. Subtract line 2 from line 1 Gifts of interests to spouse for which a marital deduction will be claimed, based on item numbers of Schedule A ~~~ Exclusions attributable to gifts on line 4 Marital deduction. Subtract line 5 from line 4 ~~~~~~~~~~~~~~~~~~~~ Charitable deduction, based on item nos. 1 Generation-skipping transfer taxes payable with this Form 79 (from Schedule D, Part 3, col. H, Total) ~~~~~~~~~~~ 11 Taxable gifts. Add lines 9 and 1. Enter here and on page 1, Part 2 - Tax Computation, line 1 Terminable Interest (QTIP) Marital Deduction. (see instructions for Schedule A, Part 4, line 4.) ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ ~~~~~~~~~~~~~~~~~~~~~~ less exclusions ~ Total deductions. Add lines 6 and 7 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Subtract line 8 from line 3 EDWARD FLEISHER ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ If a trust (or other property) meets the requirements of qualified terminable interest property under section 2523(f), and: a. The trust (or other property) is listed on Schedule A, and b. The value of the trust (or other property) is entered in whole or in part as a deduction on Schedule A, Part 4, line 4, then the donor shall be deemed to have made an election to have such trust (or other property) treated as qualified terminable interest property under section 2523(f). If less than the entire value of the trust (or other property) that the donor has included in Parts 1 and 3 of Schedule A is entered as a deduction on line 4, the donor shall be considered to have made an election only as to a fraction of the trust (or other property). The numerator of this fraction is equal to the amount of the trust (or other property) deducted on Schedule A, Part 4, line 6. The denominator is equal to the total value of the trust (or other property) listed in Parts 1 and 3 of Schedule A Page 3 2,13,. 13,. 2,,. 2,,. 2,,. If you make the QTIP election, the terminable interest property involved will be included in your spouse s gross estate upon his or her death (section 244). See instructions for line 4 of Schedule A. If your spouse disposes (by gift or otherwise) of all or part of the qualifying life income interest, he or she will be considered to have made a transfer of the entire property that is subject to the gift tax. See Transfer of Certain Life Estates Received From Spouse in the instructions. 12 Election Out of QTIP Treatment of Annuities : Check here if you elect under section 2523(f)(6) not to treat as qualified terminable interest property any joint and survivor annuities that are reported on Schedule A and would otherwise be treated as qualified terminable interest property under section 2523(f). See instructions. Enter the item numbers from Schedule A for the annuities for which you are making this election SCHEDULE B Gifts From Prior Periods If you answered "Yes" on line 11a of page 1, Part 1, see the instructions for completing Schedule B. If you answered "No," skip to the Tax Computation on page 1 (or Schedules C or D, if applicable). Complete Schedule A before beginning Schedule B. See instructions for recalculation of the column C amounts. Attach calculations. A B C D E Amount of applicable Amount of specific Internal Revenue office credit (unified credit) against exemption for prior where prior return was filed gift tax for periods after periods ending before December 31, 1976 January 1, 1977 Calendar year or calendar quarter (see instructions) Amount of taxable gifts 1 Totals for prior periods ~~~~~~~~~~~~~~~~~~~~ 1 2 Amount, if any, by which total specific exemption, line 1, column D is more than $3, ~~~~~~~~~~~~~~~~~ 2 3 Total amount of taxable gifts for prior periods. Add amount on line 1, column E and amount, if any, on line 2. Enter here and on page 1, Part 2 - Tax Computation, line 2 (If more space is needed, attach additional statements.) Form (212) FLEISHER-EDW FLEISHER, EDWARD FLEISH1

71 Form 79 (212) EDWARD FLEISHER Page 4 SCHEDULE C Deceased Spousal Unused Exclusion (DSUE) Amount Provide the following information to determine the DSUE amount and applicable credit received from prior spouses. Complete Schedule A before beginning Schedule C. A B C D E F G Name of Deceased Spouse Date of Death Portability If "Yes," DSUE RESERVED Election Amount Received (dates of death after Made? from Spouse DSUE Amount Applied by Donor to Lifetime Gifts (current and prior gifts) Date of Gift(s) (enter as mm/dd/yy for Part 1 and as yyyy for Part 2) December 31, 21 only) Yes No Part 1 - DSUE RECEIVED FROM LAST DECEASED SPOUSE BETH R TYLER 1/5/12 2,659,148.2,,. 6/14/12 Part 2 - DSUE RECEIVED FROM PREDECEASED SPOUSE(S) TOTAL (for all DSUE amounts applied for Part 1 and Part 2) 2,,. Donor s basic exclusion amount (see instructions) ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Total from column E, Parts 1 and 2 Add lines 1 and 2 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Applicable credit on amount in line 4 (See Table for Computing Gift Tax in the instructions). Enter here 1 Reserved 1 SCHEDULE D Computation of Generation-Skipping Transfer Tax Note. Inter vivos direct skips that are completely excluded by the GST exemption must still be fully reported (including value and exemptions claimed) on Schedule D. Part 1 - Generation-Skipping Transfers ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Reserved ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ and on line 7, Part 2 - Tax Computation ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Reserved ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Reserved ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Reserved ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Reserved ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ A B C D Value (from Schedule A, Nontaxable Part 2, col. H) Portion of Transfer Item No. (from Schedule A, Part 2, col. A) Net Transfer (subtract col. C from col. B) 5,12,. 2,,. 7,12,. 2,472,8. Gifts made by spouse (for gift splitting only) (If more space is needed, attach additional statements.) 79 Form (212) FLEISHER-EDW FLEISHER, EDWARD FLEISH1

72 Form 79 (212) EDWARD FLEISHER Page 5 Part 2 - GST Exemption Reconciliation (Section 2631) and Section 2652(a)(3) Election Check here if you are making a section 2652(a)(3) (special QTIP) election (see instructions) Enter the item numbers from Schedule A of the gifts for which you are making this election 1 Maximum allowable exemption (see instructions) ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 1 5,12,. 2 Total exemption used for periods before filing this return ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 2 3 Exemption available for this return. Subtract line 2 from line 1 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 3 5,12,. 4 Exemption claimed on this return from Part 3, column C total, below ~~~~~~~~~~~~~~~~~~~~~~~~~~ 4 5 Automatic allocation of exemption to transfers reported on Schedule A, Part 3 (see instructions) ~~~~~~~~~~~~~~ 5 6 Exemption allocated to transfers not shown on line 4 or 5, above. You must attach a "Notice of Allocation." (see instructions) ~ 6 7 Add lines 4, 5, and 6 ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 7 8 Exemption available for future transfers. Subtract line 7 from line 3 8 5,12,. Part 3 - Tax Computation A Item No. B C D E F G H (from Net Transfer GST Exemption Divide col. C Inclusion Ratio Maximum Applicable Rate Generation-Skipping Schedule D, (from Schedule D, Allocated by col. B (Subtract col. D Estate Tax (multiply col. E Transfer Tax Part 1) Part 1, col. D) from 1.) Rate by col. F) (multiply col. B by col. G) Gifts made by spouse (for gift splitting only) Total exemption claimed. Enter here and on Part 2, line 4, above. May not exceed Part 2, line 3, above (If more space is needed, attach additional statements.) 35% (.35) 35% (.35) 35% (.35) 35% (.35) 35% (.35) 35% (.35) 35% (.35) 35% (.35) 35% (.35) 35% (.35) 35% (.35) 35% (.35) Total generation-skipping transfer tax. Enter here; on page 3, Schedule A, Part 4, line 1; and on page 1, Part 2 - Tax Computation, line Form (212) FLEISHER-EDW FLEISHER, EDWARD FLEISH1

73 Form 76 United States Estate (and Generation-Skipping (Rev. August 212) Transfer) Tax Return OMB No Department of the Treasury Internal Revenue Service Part 1 - Decedent and Executor Part 2 - Tax Computation 1a 3a 6a 6c 7a I Estate of a citizen or resident of the United States (see instructions). To be filed for I decedents dying after December 31, 211, and before January 1, 213. Information about Form 76 and its separate instructions is at Decedent's first name and middle initial (and maiden name, if any) 1b Decedent's last name 2 Decedent's social security no. County, state, and ZIP or foreign country and postal code, of legal residence (domicile) at time of death Name of executor (see instructions) Executor's social security number (see instructions) 3b Year domicile established 4 Date of birth 5 Date of death 6b Executor's address (number and street including apartment or suite no.; city, town, or post office; state; country; and ZIP or postal code) and phone no. Phone no. 6d If there are multiple executors, check here and attach a list showing the names, addresses, telephone numbers, and SSNs of the additional executors. Name and location of court where will was probated or estate administered 7b Case number I I 8 If decedent died testate, check here and attach a certified copy of the will. 9 If you extended the time to file this Form 76, check here 1 If Schedule R-1 is attached, check here 11 If you are estimating the value of assets included in the gross estate on line 1 pursuant to the special rule of Reg. section T(a) (7)(ii), check here 1 Total gross estate less exclusion (from Part 5 - Recapitulation, item 13) mmmmmmmmmmmmmmmmmm 1 1,419,23 2 Tentative total allowable deductions (from Part 5 - Recapitulation, item 24) mmmmmmmmmmmmmmmm 2 1,323,662 3a Tentative taxable estate (subtract line 2 from line 1) mmmmmmmmmmmmmmmmmmmmmmmmmmm 3a 95,361 b State death tax deduction mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 3b 8,563 c Taxable estate (subtract line 3b from line 3a) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 3c 86,798 4 Adjusted taxable gifts (see instructions) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 4 5 Add lines 3c and 4mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 5 86,798 6 Tentative tax on the amount on line 5 from Table A in the instructions mmmmmmmmmmmmmmmmmm 6 2,13 7 Total gift tax paid or payable (see instructions) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 7 8 Gross estate tax (subtract line 7 from line 6) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 8 2,13 9a Basic exclusion amount mmmmmmmmmmmmmmmmmmmmmm 9a 5,12, 9b Deceased spousal unused exclusion (DSUE) amount from predeceased spouse(s), if any (from Section D, Part 6-Portability of Deceased Spousal Unused Exclusion) mmmmmm 9b 9c Applicable exclusion amount (add lines 9a and 9b) mmmmmmmmm 9c 5,12, 9d Applicable credit amount (tentative tax on the amount in 9c from Table A in the instructions) 9d 1,772,8 1 Adjustment to applicable credit amount (May not exceed $6,. See instructions.) mmmmmmmmmmmmmmmmmmmmmmmmmm 1 11 Allowable applicable credit amount (subtract line 1 from line 9d) mmmmmmmmmmmmmmmmmmmm 11 1,772,8 12 Subtract line 11 from line 8 (but do not enter less than zero) mmmmmmmmmmmmmmmmmmmmmmm Credit for foreign death taxes (from Schedule P). (Attach Form(s) 76-CE.) mmm Credit for tax on prior transfers (from Schedule Q) mmmmmmmmmm Total credits (add lines 13 and 14) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Net estate tax (subtract line 15 from line 12) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Generation-skipping transfer (GST) taxes payable (from Schedule R, Part 2, line 1) mmmmmmmmmmmm Total transfer taxes (add lines 16 and 17) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Prior payments (explain in an attached statement) mmmmmmmmmmmmmmmmmmmmmmmmmmmm 19 2 Balance due (or overpayment) (subtract line 19 from line 18) mmmmmmmmmmmmmmmmmmmmmmm 2 Under penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements, and to the best of my knowledge and belief, it is true, correct, and complete. Declaration of preparer other than the executor is based on all information of which preparer has any knowledge. Sign Here Jessica Delaware County Edward Fleisher Paid Preparer Use Only M M Signature of executor Signature of executor Print/Type preparer's name Firm's name Firm's address I PA - Preparer's signature Sampson Date M M Date Date Check if self-employed Firm's EIN Phone no. For Privacy Act and Paperwork Reduction Act Notice, see instructions. Form 76 (Rev ) JSA 1R81 1. I /18/1922 8/21/212 c/o Rosemont Trust Company 1 Main Street Rosemont, PA 191 Orphans Court of Delaware County, Pennsylvania ( ) - PTIN I I

74 Form 76 (Rev ) Decedent's social security number Estate of: Jessica Sampson Part 3 - Elections by the Executor Note. For information on electing portability of the decedent's DSUE amount, including how to opt out of the election, see Part 6- Portability of Deceased Spousal Unused Exclusion. Note. Some of the following elections may require the posting of bonds or liens. Please check the "Yes" or "No" box for each question (see instructions). 1 Do you elect alternate valuation? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 2 Do you elect special-use valuation? If "Yes," you must complete and attach Schedule A-1 mmmmmmmmmmmmmmmmmmmm 3 Do you elect to pay the taxes in installments as described in section 6166? mmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," you must attach the additional information described in the instructions. Note. By electing section 6166 installment payments, you may be required to provide security for estate tax deferred under section 6166 and interest in the form of a surety bond or a section 6324A lien. 3 4 Do you elect to postpone the part of the taxes due to a reversionary or remainder interest as described in section 6163? 4 mmmmm Part 4 - General Information Note. Please attach the necessary supplemental documents. You must attach the death certificate. (See instructions) Authorization to receive confidential tax information under Reg. section 61.54(b)(2)(i); to act as the estate's representative before the IRS; and to make written or oral presentations on behalf of the estate: Name of representative (print or type) State Address (number, street, and room or suite no., city, state, and ZIP code) James Doe, Esq. I declare that I am the attorney/ certified public accountant/ enrolled agent (check the applicable box) for the executor. I am not under suspension or disbarment from practice before the Internal Revenue Service and am qualified to practice in the state shown above. Signature CAF number Date Telephone number 1 Death certificate number and issuing authority (attach a copy of the death certificate to this return). P Commonwealth of Penna. 2 Decedent's business or occupation. If retired, check here and state decedent's former business or occupation. Architect pa I Buck & Doe, LLC, 15 Main Street Rosemont, PA Department of Health 3a Marital status of the decedent at time of death: Married Widow/widower Single Legally separated Divorced 3b For all prior marriages, list the name and SSN of the former spouse, the date the marriage ended, and whether the marriage ended by annulment, divorce, or death. Attach additional statements of the same size if necessary. 1 2 Yes No 4a Surviving spouse's name 4b Social security number 4c Amount received (see instructions) Edward Fleisher ,362 5 Individuals (other than the surviving spouse), trusts, or other estates who receive benefits from the estate (do not include charitable beneficiaries shown in Schedule O) (see instructions). Name of individual, trust, or estate receiving $5, or more Identifying number Relationship to decedent Amount (see instructions) Nick Lackney Brother 86,799 All unascertainable beneficiaries and those who receive less than $5, mmmmmmmmmmmmmmmmmmmmmmmmmi Total mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm If you answer "Yes" to any of the following questions, you must attach additional information as described. Yes No Is the estate filing a protective claim for refund? If "Yes," complete and attach two copies of Schedule PC for each claim. 7 Does the gross estate contain any section 244 property (qualified terminable interest property (QTIP) from a prior gift or estate)? 6 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm (see instructions)m mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 8a mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Have federal gift tax returns ever been filed? If "Yes," attach copies of the returns, if available, and furnish the following information: b Period(s) covered c Internal Revenue office(s) where filed mmmmmmmmmmmmmmmmm 9a Was there any insurance on the decedent's life that is not included on the return as part of the gross estate?m mmmmmmmmmmmm b Did the decedent own any insurance on the life of another that is not included in the gross estate? JSA 1R ,799 Page 2

75 Form 76 (Rev ) Decedent's social security number Estate of: Jessica Sampson Part 4 - General Information (continued) If you answer "Yes" to any of the following questions, you must attach additional information as described. Yes No 1 Did the decedent at the time of death own any property as a joint tenant with right of survivorship in which (a) one or more of the other joint tenants was someone other than the decedent's spouse, and (b) less than the full value of the property is included on the return as part of the gross estate? If "Yes," you must complete and attach Schedule E mmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmm complete and attach Schedule G mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 11a Did the decedent, at the time of death, own any interest in a partnership (for example, a family limited partnership), an unincorporated business, or a limited liability company; or own any stock in an inactive or closely held corporation? b If "Yes," was the value of any interest owned (from above) discounted on this estate tax return? If "Yes," see the instructions on reporting the total accumulated or effective discounts taken on Schedule F or G 12 Did the decedent make any transfer described in sections 235, 236, 237, or 238? (see instructions) If "Yes," you must 13a Were there in existence at the time of the decedent's death any trusts created by the decedent during his or her lifetime? mmmmmmmm b Were there in existence at the time of the decedent's death any trusts not created by the decedent under which the decedent possessed any power, beneficial interest, or trusteeship? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmm c Was the decedent receiving income from a trust created after October 22, 1986, by a parent or grandparent? If "Yes," was there a GST taxable termination (under section 2612) on the death of the decedent? d If there was a GST taxable termination (under section 2612), attach a statement to explain. Provide a copy of the trust or will creating the trust, and give the name, address, and phone number of the current trustee(s). e Did the decedent at any time during his or her lifetime transfer or sell an interest in a partnership, limited liability company, or closely held corporation to a trust described in lines 13a or 13b?m mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," provide the EIN for this transferred/sold item. I 14 Did the decedent ever possess, exercise, or release any general power of appointment? If "Yes," you must complete and attach Schedule Hm mmmmmmmm 15 Did the decedent have an interest in or a signature or other authority over a financial account in a foreign country, such as a bank account, securities account, or other financial account? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 16 Was the decedent, immediately before death, receiving an annuity described in the "General" paragraph of the instructions for Schedule I or a private annuity? If "Yes," you must complete and attach Schedule I mmmmmmmmmmmmmmmmmmmmmmmmmmm 17 Was the decedent ever the beneficiary of a trust for which a deduction was claimed by the estate of a predeceased spouse under section 256(b)(7) and which is not reported on this return? If "Yes," attach an explanation mmmmmmmmmmmmmmmmmmmm Part 5 - Recapitulation. Note. If estimating the value of one or more assets pursuant to the special rule of Reg. section T(a)(7)(ii), enter on both lines 1 and 23 the amount noted in the instructions for the corresponding range of values. (See instructions for details.) mmmmmmmmmmmmmmmmmmmmmmmmmm Item no. Gross estate Alternate value Value at date of death 1 Schedule A - Real Estate 1 2 Schedule B - Stocks and Bonds mmmmmmmmmmmmmmmmmmmmmmm 2 3 Schedule C - Mortgages, Notes, and Cash mmmmmmmmmmmmmmmmmm 3 4 Schedule D - Insurance on the Decedent's Life (attach Form(s) 712) mmmmm 4 5 Schedule E - Jointly Owned Property (attach Form(s) 712 for life insurance) mm 5 6 Schedule F - Other Miscellaneous Property (attach Form(s) 712 for life insurance) 6 7 Schedule G - Transfers During Decedent's Life (att. Form(s) 712 for life insurance) mm 7 8 Schedule H - Powers of Appointment 8 9 Schedule I - Annuities mmmmmmmmmmmmmmmmmmmmmmmmmmm 9 1 Estimated value of assets subject to the special rule of Reg. section T(a)(7)(ii) m 1 11 Total gross estate (add items 1 through 1) mmmmmmmmmmmmmmmmm Schedule U - Qualified Conservation Easement Exclusion mmmmmmmmmm Total gross estate less exclusion (subtract item 12 from item 11). Enter here and on line 1 of Part 2 - Tax Computation mmmmmmmmmmmmmmmmmm 13 Item no. Deductions Amount 14 Schedule J - Funeral Expenses and Expenses Incurred in Administering Property Subject to Claims Schedule K - Debts of the Decedent mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmm Schedule K - Mortgages and Liens mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Total of items 14 through 16 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Allowable amount of deductions from item 17 (see the instructions for item 18 of the Recapitulation) mmmm Schedule L - Net Losses During Administrationmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 19 2 Schedule L - Expenses Incurred in Administering Property Not Subject to Claimsmmmmmmmmmmmmmmm 2 21 Schedule M - Bequests, etc., to Surviving Spousemmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Schedule O - Charitable, Public, and Similar Gifts and Bequests mmmmmmmmmmmmmmmmmmmmmmm Estimated value of deductible assets subject to the special rule of Reg. section T(a)(7)(ii) mmmmmm Tentative total allowable deductions (add items 18 through 23). Enter here and on line 2 of the Tax Computation 24 JSA 145,23 24, 1,25, 1,419,23 1,419,23 2,3 2,3 2,3 71,362 1,25, 1,323,662 1R Page 3 75

76 Form 76 (Rev ) Decedent's social security number Estate of: Jessica Sampson Part 6 - Portability of Deceased Spousal Unused Exclusion (DSUE) Portability Election A decedent with a surviving spouse elects portability of the deceased spousal unused exclusion (DSUE) amount, if any, by completing and timely-filing this return. No further action is required to elect portability of the DSUE amount to allow the surviving spouse to use the decedent's DSUE amount. Section A. Opting Out of Portability The estate of a decedent with a surviving spouse may opt out of electing portability of the DSUE amount. Check here and do no complete Sections B and C of Part 6 only if the estate opts NOT to elect portability of the DSUE amount. Section B. QDOT Yes No Are any assets of the estate being transferred to a qualified domestic trust (QDOT)? mmmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," the DSUE amount portable to a surviving spouse (calculated in Section C, below) is preliminary and shall be redetermined at the time of the final distribution or other taxable event imposing estate tax under section 256A. See instructions for more details. Section C. DSUE Amount Portable to the Surviving Spouse (To be completed by the estate of a decedent making a portability election.) Complete the following calculation to determine the DSUE amount that can be transferred to the surviving spouse. 1 1 Enter amount from line 9c, Part 2 - Tax Computationm mmmmmmmmmmmmmmmmmmmmmmmmmmmm 2 Enter amount from line 7, Part 2 - Tax Computation 2 mmmmmmmmmmmmmmmmmmmmmmmmmmmmm 3 Divide amount on line 2 by 35% (.35). (do not enter less than zero) 3 mmmmmmmmmmmmmmmmmmmmm 4 Add lines 1 and 3 4 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 5 Enter the amount from line 5, Part 2 - Tax Computation 5 mmmmmmmmmmmmmmmmmmmmmmmmmmm 6 Subtract line 5 from line 4 (do not enter less than zero) mmmmmmmmmmmmmmmmmmmmmmmmmmmm 6 7 DSUE amount portable to the surviving spouse (Enter the lesser of line 6 or line 9a, Part 2 - Tax Computation) 7 5,12, 5,12, 86,798 5,33,22 5,33,22 Section D. DSUE Amount Received from Predeceased Spouse(s) (To be completed by the estate of a deceased surviving spouse with DSUE amount from predeceased spouse(s)) Provide the following information to determine the DSUE amount received from deceased spouses. A Name of Deceased Spouse (dates of death after December 31, 21, only) B Date of Death (enter as mm/dd/yy) C Portability Election Made? D If "Yes," DSUE Amount Received from Spouse E DSUE Amount Applied by Decedent to Lifetime Gifts F Year of Form 79 Reporting Use of DSUE Amount Listed in col E G Remaining DSUE Amount, if any (subtract col. E from col. D) Yes Part 1 - DSUE RECEIVED FROM LAST DECEASED SPOUSE No Part 2 - DSUE RECEIVED FROM OTHER PREDECEASED SPOUSE(S) AND USED BY DECEDENT Total (for all DSUE amounts from predeceased spouse(s) applied) mmmmmmmmmmm Add the amount from Part 1, column D and the total from Part 2 column E. Enter the result on line 9b, Part 2-Tax Computation mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm I JSA Page 4 1R

77 Estate of: Jessica Sampson Form 76 Page 4, Part 6, Section D, DSUE Amount Received from Predeceased Spouse(s) C E B Portability D DSUE AMount F G A Date Election DSUE Amount Applied to Year of Form Remaining Name of Deceased Spouse of Death Made? Received Lifetime Gifts 79 Reporting DSUE Amount Yes No Part 1 - DSUE Received from Last Deceased Spouse None Part 2 - DSUE Received from Other Predeceased Spouse(s) and Used by Decedent None Total (for all DSUE amounts applied) Add amount from Part 1, Column D and Total of Part 2, Column E 77

78 Form 76 (Rev ) Decedent's social security number Estate of: Jessica Sampson SCHEDULE D - Insurance on the Decedent's Life You must list all policies on the life of the decedent and attach a Form 712 for each policy. Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T(a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entries in the last three columns. Item number Description Alternate valuation date Alternate value Value at date of death 1 Aetna Life Insurance Company Whole Life Policy #4555 Beneficiary: Nick Lackney (brother) 24, mmmmm mmmmmmmmmmmmmmmmm Total from continuation schedules (or additional statements) attached to this schedule TOTAL. (Also enter on Part 5 - Recapitulation, page 3, at item 4.) 24, (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) JSA Schedule D - Page 12 1R

79 Form 76 (Rev ) Decedent's social security number Estate of: Jessica Sampson SCHEDULE E - Jointly Owned Property (If you elect section 232A valuation, you must complete Schedule E and Schedule A-1.) PART 1. Qualified Joint Interests - Interests Held by the Decedent and His or Her Spouse as the Only Joint Tenants (Section 24(b)(2)) Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T(a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entries in the last three columns. Item number Description. For securities, give CUSIP number. If trust, partnership, or closely held entity, give EIN. Alternate valuation date Alternate value Value at date of death CUSIP number or EIN, where applicable 1 House and lot located at 23 Lowry's Lane, Rosemont, PA 2 Personal property located at 23 Lowry's Lane, Rosemont, Pennsylvania 191 1a 1b Total from continuation schedules (or additional statements) attached to this schedule mmmmm Totals mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Amounts included in gross estate (one-half of line 1a)m mmmmmmmmmmmmmmmmmmmm PART 2. 2a All Other Joint Interests State the name and address of each surviving co-tenant. If there are more than three surviving co-tenants, list the additional cotenants on an attached statement. 1a 1b Name Address (number and street, city, state, and ZIP code) A. B. C. Item number Enter letter for co-tenant Description (including alternate valuation date if any). For securities, give CUSIP number. If trust, partnership, or closely held entity, give EIN Percentage includible Includible alternate value Includible value at date of death None CUSIP number or EIN, where applicable Total from continuation schedules (or additional statements) attached to this schedule mmmmm 2b Total other joint interests mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 2b 3 Total includible joint interests (add lines 1b and 2b). Also enter on Part 5 - Recapitulation, page 3, at item 5mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 3 (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) JSA Schedule E - Page 13 1R

80 Form 76 (Rev ) Decedent's social security number Estate of: Jessica Sampson SCHEDULE F - Other Miscellaneous Property Not Reportable Under Any Other Schedule (For jointly owned property that must be disclosed on Schedule E, see instructions.) (If you elect section 232A valuation, you must complete Schedule F and Schedule A-1.) Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T(a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entries in the last three columns. 1 Did the decedent own any works of art, items, or any collections whose artistic or collectible value at date of death exceeded $3,? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," submit full details on this schedule and attach appraisals. 2 Has the decedent's estate, spouse, or any other person received (or will receive) any bonus or award as a result of the decedent's employment or death?m mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," submit full details on this schedule. 3 Did the decedent at the time of death have, or have access to, a safe deposit box? mmmmmmmmmmmmmmmmmmmmm If "Yes," state location, and if held jointly by decedent and another, state name and relationship of joint depositor. Yes No If any of the contents of the safe deposit box are omitted from the schedules in this return, explain fully why omitted. Item number Description. For securities, give CUSIP number. If trust, partnership, or closely held entity, give EIN CUSIP number or EIN, where applicable Alternate valuation date Alternate value Value at date of death 1 Jewelry (These items pass to the surviving spouse under Article II of Decedent's Will) 2 Record Collection (This passes to the surviving spouse under Article II of the Decedent's Will) mmmm mmmmmmmmmmmmmmmm Total from continuation schedules (or additional statements) attached to this schedule TOTAL. (Also enter on Part 5 - Recapitulation, page 3, at item 6.) (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) JSA 1R Schedule F - Page 14 8

81 Form 76 (Rev ) Decedent's social security number Estate of: Jessica Sampson SCHEDULE G - Transfers During Decedent's Life (If you elect section 232A valuation, you must complete Schedule G and Schedule A-1.) Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T(a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entries in the last three columns. Item number Description. For securities, give CUSIP number. If trust, partnership, or closely held entity, give EIN Alternate valuation date Alternate value Value at date of death A. Gift tax paid or payable by the decedent or the estate for all gifts made by the decedent or his or her spouse within 3 years before the decedent's death (section 235(b))m mmmmmmmmmmmmmmmmmmmm B. Transfers includible under sections 235(a), 236, 237, or 238: 1 Decedent created the Jessica Sampson Charitable Remainder Unitrust dated 1/1/1974. Decedent received the unitrust payments during her lifetime. The trust now terminates to the University of Pennsylvania Museum. Total from continuation schedules (or additional statements) attached to this schedule mmmmm TOTAL. (Also enter on Part 5 - Recapitulation, page 3, at item 7.) mmmmmmmmmmmmmmmmm SCHEDULE H - Powers of Appointment (Include "5 and 5 lapsing" powers (section 241(b)(2)) held by the decedent.) (If you elect section 232A valuation, you must complete Schedule H and Schedule A-1.) Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T(a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entries in the last three columns. Item number None Description Alternate valuation date Alternate value Value at date of death Total from continuation schedules (or additional statements) attached to this schedule mmmmmmm TOTAL. (Also enter on Part 5 - Recapitulation, page 3, at item 8.)m mmmmmmmmmmmmmmmmmm (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) JSA Schedules G and H - Page 15 1R

82 Form 76 (Rev ) Decedent's social security number Estate of: Jessica Sampson SCHEDULE J I- Funeral Expenses and Expenses Incurred in Administering Property Subject to Claims Use Schedule PC to make a protective claim for refund due to an expense not currently deductible. For such a claim, report the expense on Schedule J but without a value in the last column. Note. Do not list expenses of administering property not subject to claims on this schedule. To report those expenses, see instructions. If executors' commissions, attorney fees, etc., are claimed and allowed as a deduction for estate tax purposes, they are not allowable as a deduction in computing the taxable income of the estate for federal income tax purposes. They are allowable as an income tax deduction on Form 141, U.S. Income Tax Return for Estates and Trusts, if a waiver is filed to forgo the deduction on Form 76 (see Instructions for Form 141). Are you aware of any actual or potential reimbursement to the estate of any expense claimed as a deduction on this Yes No schedule? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," attach a statement describing the expense(s) subject to potential reimbursement. (see instructions) Item Description Expense amount Total amount number A. Funeral expenses: 1 Harrisburg Crematory Services 2,3 Total from continuation schedules Total funeral expenses mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm I 2,3 B. Administration expenses: 1 Executors' commissions - amount estimated/agreed upon/paid. (Strike out the words that do not apply.) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 2 Attorney fees - amount estimated/agreed upon/paid. (Strike out the words that do not apply.) mmmmm 3 Accountant fees - amount estimated/agreed upon/paid. (Strike out the words that do not apply.)m mmm 4 Miscellaneous expenses: None Expense amount Total miscellaneous expenses from continuation schedules (or additional statements) attached to this schedule mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Total miscellaneous expenses mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmi mmmmmmmmmmmmmmmmmmmmmmmmi TOTAL. (Also enter on Part 5 Recapitulation, page 3, at item 14.) 2,3 (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) Schedule J - Page 17 JSA 1R

83 Form 76 (Rev ) Estate of: Jessica Sampson SCHEDULE M - Bequests, etc., to Surviving Spouse Decedent's social security number Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T (a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entry in the last column. Yes No 1 Did any property pass to the surviving spouse as a result of a qualified disclaimer? mmmmmmmmmmmmmmmmmmm 1 If "Yes," attach a copy of the written disclaimer required by section 2518(b). 2a In what country was the surviving spouse born? USA b What is the surviving spouse's date of birth? 1/1/1921 c Is the surviving spouse a U.S. citizen? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 2c d If the surviving spouse is a naturalized citizen, when did the surviving spouse acquire citizenship? e If the surviving spouse is not a U.S. citizen, of what country is the surviving spouse a citizen? 3 Election Out of QTIP Treatment of Annuities. Do you elect under section 256(b)(7)(C)(ii) not to treat as qualified terminable interest property any joint and survivor annuities that are included in the gross estate and would otherwise be treated as qualified terminable interest property under section 256(b)(7)(C)? (see instructions) mmmm Item Description of property interests passing to surviving spouse. number For securities, give CUSIP number. If trust, partnership, or closely held entity, give EIN QTIP property: None Amount All other property: 2A One Half of Residue 71,362 2B 5% of House and lot located at 23 Lowry's Lane, Rosemont, PA 2C 5% of Personal property located at 23 Lowry's Lane, Rosemont, Pennsylvania 191 2D 1% of Jewelry 2E 1% of Record Collection Total from continuation schedules (or additional statements) attached to this schedule mmmmmmmmmmmmmm 4 Total amount of property interests listed on Schedule Mmmmmmmmmmmmmmmmmmmmmmmmmmmm 4 5a Federal estate taxes payable out of property interests listed on Schedule M mmmmmm 5a b Other death taxes payable out of property interests listed on Schedule Mmmmmmmmm 5b c Federal and state GST taxes payable out of property interests listed on Schedule M 5c d Add items 5a, 5b, and 5cm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 6 Net amount of property interests listed on Schedule M (subtract 5d from 4). Also enter on Part 5 - Recapitulation, page 3, at item 21 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 6 71,362 (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) JSA Schedule M - Page 2 1R d 71,362

84 Form 76 (Rev ) Decedent's social security number Estate of: Jessica Sampson SCHEDULE O - Charitable, Public, and Similar Gifts and Bequests Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T (a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entry in the last column. Yes No 1a If the transfer was made by will, has any action been instituted to contest or have interpreted any of its provisions b affecting the charitable deductions claimed in this schedule? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," full details must be submitted with this schedule. According to the information and belief of the person or persons filing this return, is any such action planned? mmmmm If "Yes," full details must be submitted with this schedule. 2 Did any property pass to charity as the result of a qualified disclaimer? mmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," attach a copy of the written disclaimer required by section 2518(b). Item number Name and address of beneficiary Character of institution 1 University of Pennsylvania Museum 1% of Decedent created the Jessica Sampson Charitable Remainder Unitrust dated 1/1/1974. Decedent received the unitrust payments during her lifetime. The trust now terminates to the University of Pennsylvania Museum. Educational Amount Total from continuation schedules (or additional statements) attached to this schedule mmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmm mmmmmmmmmm mmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 3 Total 3 4a Federal estate tax payable out of property interests listed above 4a b Other death taxes payable out of property interests listed above 4b c Federal and state GST taxes payable out of property interests listed above 4c d Add items 4a, 4b, and 4c 4d 5 Net value of property interests listed above (subtract 4d from 3). Also enter on Part 5 - Recapitulation, page 3, at item 22 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 5 (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) Schedule O - Page 21 JSA 1R

85 Table of Estimated Values from page 16 of 212 Form 76 Instructions Under the special rule of T(a)(7)(ii), the Executor can estimate the value of assets eligible for the marital or charitable deduction if filing a 76 for portability purposes only. The assets are listed on the appropriate Schedule without a value, and then totaled using the chart below to be added to the Recapitulation lines on Page 3, Part 5, lines 1 and 23. If the total estimated value of the assets eligible for the special rule under Reg. section T(a)(7)(ii) is more than But less than or equal to Include this amount on lines 1 and 23: $ $25, $25, $25, $5, $5, $5, $75, $75, $75, $1,, $1,, $1,, $1,25, $1,25, $1,25, $1,5, $1,5, $1,5, $1,75, $1,75, $1,75, $2,, $2,, $2,, $2,25, $2,25, $2,25, $2,5, $2,5, $2,5, $2,75, $2,75, $2,75, $3,, $3,, $3,, $3,25, $3,25, $3,25, $3,5, $3,5, $3,5, $3,75, $3,75, $3,75, $4,, $4,, $4,, $4,25, $4,25, $4,25, $4,5, $4,5, $4,5, $4,75, $4,75, $4,75, $5,, $5,, $5,, $5,12, $5,12, 85

86 Form 76 United States Estate (and Generation-Skipping (Rev. August 212) Transfer) Tax Return OMB No Department of the Treasury Internal Revenue Service I Estate of a citizen or resident of the United States (see instructions). To be filed for decedents dying after December 31, 211, and before January 1, 213. about Form 76 and its separate instructions is at IInformation Decedent's first name and middle initial (and maiden name, if any) 1b Decedent's last name 2 Decedent's social security no. 1a PRIOR Edward YEAR FORM Part 1 - Decedent and Executor Part 2 - Tax Computation 3a 6a 6c 7a County, state, and ZIP or foreign country and postal code, of legal residence (domicile) at time of death Name of executor (see instructions) Executor's social security number (see instructions) 3b Year domicile established 4 Date of birth 5 Date of death 6b Executor's address (number and street including apartment or suite no.; city, town, or post office; state; country; and ZIP or postal code) and phone no. Phone no. 6d If there are multiple executors, check here and attach a list showing the names, addresses, telephone numbers, and SSNs of the additional executors. Name and location of court where will was probated or estate administered 7b Case number I I 8 If decedent died testate, check here and attach a certified copy of the will. 9 If you extended the time to file this Form 76, check here 1 If Schedule R-1 is attached, check here 11 If you are estimating the value of assets included in the gross estate on line 1 pursuant to the special rule of Reg. section T(a) (7)(ii), check here 1 Total gross estate less exclusion (from Part 5 - Recapitulation, item 13) mmmmmmmmmmmmmmmmmm 1 17,, 2 Tentative total allowable deductions (from Part 5 - Recapitulation, item 24) mmmmmmmmmmmmmmmm 2 43, 3a Tentative taxable estate (subtract line 2 from line 1) mmmmmmmmmmmmmmmmmmmmmmmmmmm 3a 16,957, b State death tax deduction mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 3b 763,65 c Taxable estate (subtract line 3b from line 3a) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 3c 16,193,935 4 Adjusted taxable gifts (see instructions) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 4 2,, 5 Add lines 3c and 4mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 5 18,193,935 6 Tentative tax on the amount on line 5 from Table A in the instructions mmmmmmmmmmmmmmmmmm 6 7,223,374 7 Total gift tax paid or payable (see instructions) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 7 8 Gross estate tax (subtract line 7 from line 6) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 8 7,223,374 9a Basic exclusion amount mmmmmmmmmmmmmmmmmmmmmm 9a 5,25, 9b Deceased spousal unused PRIOR exclusion (DSUE) amount from predeceased spouse(s), YEAR if FORM any (from Section D, Part 6-Portability of Deceased Spousal Unused Exclusion) mmmmmm 9b 7,33,22 9c Applicable exclusion amount (add lines 9a and 9b) mmmmmmmmm 9c 12,283,22 9d Applicable credit amount (tentative tax on the amount in 9c from Table A in the instructions) 9d 4,859,81 1 Adjustment to applicable credit amount (May not exceed $6,. See instructions.) mmmmmmmmmmmmmmmmmmmmmmmmmm 1 11 Allowable applicable credit amount (subtract line 1 from line 9d) mmmmmmmmmmmmmmmmmmmm 11 4,859,81 12 Subtract line 11 from line 8 (but do not enter less than zero) mmmmmmmmmmmmmmmmmmmmmmm 12 2,364, Credit for foreign death taxes (from Schedule P). (Attach Form(s) 76-CE.) mmm Credit for tax on prior transfers (from Schedule Q) mmmmmmmmmm ,27 15 Total credits (add lines 13 and 14) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm ,27 16 Net estate tax (subtract line 15 from line 12) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 16 1,538, Generation-skipping transfer (GST) taxes payable (from Schedule R, Part 2, line 1) mmmmmmmmmmmm Total transfer taxes (add lines 16 and 17) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 18 1,538, Prior payments (explain in an attached statement) mmmmmmmmmmmmmmmmmmmmmmmmmmmm 19 2 Balance due (or overpayment) (subtract line 19 from line 18) mmmmmmmmmmmmmmmmmmmmmmm 2 1,538,266 Under penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements, and to the best of my knowledge and belief, it is true, correct, and complete. Declaration of preparer other than the executor is based on all information of which preparer has any knowledge. Sign Here Delaware County Bubbles Barton Paid Preparer Use Only M M Signature of executor Signature of executor Print/Type preparer's name Firm's name Firm's address I PA 191- Preparer's signature Fleisher 25 Bethlehem Pike Allentown, PA 1813 self-employed Firm's EIN PRIOR YEAR Phone FORM I no. For Privacy Act and Paperwork Reduction Act Notice, see instructions. Form 76 (Rev ) JSA 1R81 1. Date M M Date Date Check /2/213 Orphans Court of Delaware County, Pennsylvania ( ) - if PTIN I I

87 Form 76 (Rev ) Note. Some of the following elections may require the posting of bonds or liens. Please check the "Yes" or "No" box for each question (see instructions). PRIOR YEAR FORM PRIOR YEAR FORM Decedent's social security number Estate of: Edward Fleisher Part 3 - Elections by the Executor Note. For information on electing portability of the decedent's DSUE amount, including how to opt out of the election, see Part 6- Portability of Deceased Spousal Unused Exclusion. 1 Do you elect alternate valuation? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 2 Do you elect special-use valuation? If "Yes," you must complete and attach Schedule A-1 mmmmmmmmmmmmmmmmmmmm 3 Do you elect to pay the taxes in installments as described in section 6166? mmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," you must attach the additional information described in the instructions. Note. By electing section 6166 installment payments, you may be required to provide security for estate tax deferred under section 6166 and interest in the form of a surety bond or a section 6324A lien. 3 4 Do you elect to postpone the part of the taxes due to a reversionary or remainder interest as described in section 6163? 4 mmmmm Part 4 - General Information Note. Please attach the necessary supplemental documents. You must attach the death certificate. (See instructions) Authorization to receive confidential tax information under Reg. section 61.54(b)(2)(i); to act as the estate's representative before the IRS; and to make written or oral presentations on behalf of the estate: Name of representative (print or type) State Address (number, street, and room or suite no., city, state, and ZIP code) James Doe, Esq. I declare that I am the attorney/ certified public accountant/ enrolled agent (check the applicable box) for the executor. I am not under suspension or disbarment from practice before the Internal Revenue Service and am qualified to practice in the state shown above. Signature CAF number Date Telephone number 1 Death certificate number and issuing authority (attach a copy of the death certificate to this return). P Commonwealth of Penna. 2 Decedent's business or occupation. If retired, check here and state decedent's former business or occupation. Professional Bridge Player PA I Buck & Doe, LLC, 15 Main Street Rosemont, PA Department of Health 3a Marital status of the decedent at time of death: Married Widow/widower Single Legally separated Divorced 3b For all prior marriages, list the name and SSN of the former spouse, the date the marriage ended, and whether the marriage ended by annulment, divorce, or death. Attach additional statements of the same size if necessary. Beth R. Tyler SSN: marriage ended by death on 1/5/212 Jessica Sampson SSN: marriage ended by death on 8/21/ Yes No 4a Surviving spouse's name 4b Social security number 4c Amount received (see instructions) None 5 Individuals (other than the surviving spouse), trusts, or other estates who receive benefits from the estate (do not include charitable beneficiaries shown in Schedule O) (see instructions). Name of individual, trust, or estate receiving $5, or more Identifying number Relationship to decedent Amount (see instructions) Bubbles Barton Daughter 14,655,669 All unascertainable beneficiaries and those who receive less than $5, mmmmmmmmmmmmmmmmmmmmmmmmmi Total mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm If you answer "Yes" to any of the following questions, you must attach additional information as described. Yes No Is the estate filing a protective claim for refund? If "Yes," complete and attach two copies of Schedule PC for each claim. 7 Does the gross estate contain any section 244 property (qualified terminable interest property (QTIP) from a prior gift or estate)? 6 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm (see instructions)m mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 8a mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Have federal gift tax returns ever been filed? If "Yes," attach copies of the returns, if available, and furnish the following information: PRIOR YEAR FORM b Period(s) covered c Internal Revenue office(s) where filed See Attached 9a Was there any insurance on the decedent's life that is not included on the return as part of the gross estate?m mmmmmmmmmmmm b Did the decedent own any insurance on the life of another that is not included in the gross estate? See Attached JSA 1R mmmmmmmmmmmmmmmmm 14,655,669 Page 2

88 Estate of: Edward Fleisher Cincinnati, OH Page 2, Part 4 General Information, lines 8b and 8c 88

89 Form 76 (Rev ) 1 PRIOR YEAR FORM PRIOR YEAR FORM Decedent's social security number Estate of: Edward Fleisher Part 4 - General Information (continued) If you answer "Yes" to any of the following questions, you must attach additional information as described. Yes No Did the decedent at the time of death own any property as a joint tenant with right of survivorship in which (a) one or more of the other joint tenants was someone other than the decedent's spouse, and (b) less than the full value of the property is included on the return as part of the gross estate? If "Yes," you must complete and attach Schedule E mmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmm mmmmmmmmmmmmmmmmmmmmmmmmmmmm complete and attach Schedule G mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 11a Did the decedent, at the time of death, own any interest in a partnership (for example, a family limited partnership), an unincorporated business, or a limited liability company; or own any stock in an inactive or closely held corporation? b If "Yes," was the value of any interest owned (from above) discounted on this estate tax return? If "Yes," see the instructions on reporting the total accumulated or effective discounts taken on Schedule F or G 12 Did the decedent make any transfer described in sections 235, 236, 237, or 238? (see instructions) If "Yes," you must 13a Were there in existence at the time of the decedent's death any trusts created by the decedent during his or her lifetime? mmmmmmmm b Were there in existence at the time of the decedent's death any trusts not created by the decedent under which the decedent possessed any power, beneficial interest, or trusteeship? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmm mmmmmmmmmmmmmm c Was the decedent receiving income from a trust created after October 22, 1986, by a parent or grandparent? If "Yes," was there a GST taxable termination (under section 2612) on the death of the decedent? d If there was a GST taxable termination (under section 2612), attach a statement to explain. Provide a copy of the trust or will creating the trust, and give the name, address, and phone number of the current trustee(s). e Did the decedent at any time during his or her lifetime transfer or sell an interest in a partnership, limited liability company, or closely held corporation to a trust described in lines 13a or 13b?m mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," provide the EIN for this transferred/sold item. I 14 Did the decedent ever possess, exercise, or release any general power of appointment? If "Yes," you must complete and attach Schedule Hm mmmmmmmm 15 Did the decedent have an interest in or a signature or other authority over a financial account in a foreign country, such as a bank account, securities account, or other financial account? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 16 Was the decedent, immediately before death, receiving an annuity described in the "General" paragraph of the instructions for Schedule I or a private annuity? If "Yes," you must complete and attach Schedule I mmmmmmmmmmmmmmmmmmmmmmmmmmm 17 Was the decedent ever the beneficiary of a trust for which a deduction was claimed by the estate of a predeceased spouse under section 256(b)(7) and which is not reported on this return? If "Yes," attach an explanation mmmmmmmmmmmmmmmmmmmm Part 5 - Recapitulation. Note. If estimating the value of one or more assets pursuant to the special rule of Reg. section T(a)(7)(ii), enter on both lines 1 and 23 the amount noted in the instructions for the corresponding range of values. (See instructions for details.) Item no. Gross estate Alternate value Value at date of death 1 Schedule A - Real Estate mmmmmmmmmmmmmmmmmmmmmmmmmm 1 2 Schedule B - Stocks and Bonds mmmmmmmmmmmmmmmmmmmmmmm 2 3 Schedule C - Mortgages, Notes, and Cash mmmmmmmmmmmmmmmmmm 3 4 Schedule D - Insurance on the Decedent's Life (attach Form(s) 712) mmmmm 4 5 Schedule E - Jointly Owned Property (attach Form(s) 712 for life insurance) mm 5 6 Schedule F - Other Miscellaneous Property (attach Form(s) 712 for life insurance) 6 7 Schedule G - Transfers During Decedent's Life (att. Form(s) 712 for life insurance) mm 7 8 Schedule H - Powers of Appointment 8 9 Schedule I - Annuities mmmmmmmmmmmmmmmmmmmmmmmmmmm 9 1 Estimated value of assets subject to the special rule of Reg. section T(a)(7)(ii) m 1 11 Total gross estate (add items 1 through 1) mmmmmmmmmmmmmmmmm Schedule U - Qualified Conservation Easement Exclusion mmmmmmmmmm Total gross estate less exclusion (subtract item 12 from item 11). Enter here and on line 1 of Part 2 - Tax Computation mmmmmmmmmmmmmmmmmm 13 Item no. Deductions Amount 14 Schedule J - Funeral Expenses and Expenses Incurred in Administering Property Subject to Claims Schedule K - Debts of the Decedent mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm mmmmmm Schedule K - Mortgages and Liens mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Total of items 14 through 16 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Allowable amount of deductions from item 17 (see the instructions for item 18 of the Recapitulation) mmmm Schedule L - Net Losses During Administrationmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 19 2 Schedule L - Expenses Incurred in Administering Property Not Subject to Claimsmmmmmmmmmmmmmmm 2 21 Schedule M - Bequests, etc., to Surviving Spouse PRIOR mmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Schedule O - Charitable, Public, and Similar Gifts and Bequests mmmmmmmmmmmmmmmmmmmmmmm YEAR FORM Estimated value of deductible assets subject to the special rule of Reg. section T(a)(7)(ii) mmmmmm Tentative total allowable deductions (add items 18 through 23). Enter here and on line 2 of the Tax Computation 24 JSA 43, 1R Page ,, 17,, 17,, 43, 43, 43,

90 Form 76 (Rev ) Portability Election PRIOR YEAR FORM PRIOR YEAR FORM E C D Decedent's social security number Estate of: Edward Fleisher Part 6 - Portability of Deceased Spousal Unused Exclusion (DSUE) A decedent with a surviving spouse elects portability of the deceased spousal unused exclusion (DSUE) amount, if any, by completing and timely-filing this return. No further action is required to elect portability of the DSUE amount to allow the surviving spouse to use the decedent's DSUE amount. Section A. Opting Out of Portability The estate of a decedent with a surviving spouse may opt out of electing portability of the DSUE amount. Check here and do no complete Sections B and C of Part 6 only if the estate opts NOT to elect portability of the DSUE amount. Section B. QDOT Yes No Are any assets of the estate being transferred to a qualified domestic trust (QDOT)? mmmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," the DSUE amount portable to a surviving spouse (calculated in Section C, below) is preliminary and shall be redetermined at the time of the final distribution or other taxable event imposing estate tax under section 256A. See instructions for more details. Section C. DSUE Amount Portable to the Surviving Spouse (To be completed by the estate of a decedent making a portability election.) Complete the following calculation to determine the DSUE amount that can be transferred to the surviving spouse. 1 1 Enter amount from line 9c, Part 2 - Tax Computationm mmmmmmmmmmmmmmmmmmmmmmmmmmmm 2 Enter amount from line 7, Part 2 - Tax Computation 2 mmmmmmmmmmmmmmmmmmmmmmmmmmmmm 3 Divide amount on line 2 by 35% (.35). (do not enter less than zero) 3 mmmmmmmmmmmmmmmmmmmmm 4 Add lines 1 and 3 4 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 5 Enter the amount from line 5, Part 2 - Tax Computation 5 mmmmmmmmmmmmmmmmmmmmmmmmmmm 6 Subtract line 5 from line 4 (do not enter less than zero) mmmmmmmmmmmmmmmmmmmmmmmmmmmm 6 7 DSUE amount portable to the surviving spouse (Enter the lesser of line 6 or line 9a, Part 2 - Tax Computation) Section D. DSUE Amount Received from Predeceased Spouse(s) (To be completed by the estate of a deceased surviving spouse with DSUE amount from predeceased spouse(s)) Provide the following information to determine the DSUE amount received from deceased spouses. A Name of Deceased Spouse (dates of death after December 31, 21, only) B Date of Death (enter as mm/dd/yy) Portability Election Made? Yes Part 1 - DSUE RECEIVED FROM LAST DECEASED SPOUSE See attached No If "Yes," DSUE Amount Received from Spouse Part 2 - DSUE RECEIVED FROM OTHER PREDECEASED SPOUSE(S) AND USED BY DECEDENT See attached DSUE Amount Applied by Decedent to Lifetime Gifts 7 F Year of Form 79 Reporting Use of DSUE Amount Listed in col E G Remaining DSUE Amount, if any (subtract col. E from col. D) Total (for all DSUE amounts from predeceased spouse(s) applied) mmmmmmmmmmm Add the amount from Part 1, column D and the total from Part 2 column E. Enter the result on line 9b, Part 2-Tax Computation mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm PRIOR YEAR FORM JSA Page 4 1R I 7,33,22

91 Estate of: Edward Fleisher Form 76 Page 4, Part 6, Section D, DSUE Amount Received from Predeceased Spouse(s) C E B Portability D DSUE AMount F G A Date Election DSUE Amount Applied to Year of Form Remaining Name of Deceased Spouse of Death Made? Received Lifetime Gifts 79 Reporting DSUE Amount Yes No Part 1 - DSUE Received from Last Deceased Spouse JESSICA SAMPSON 8/21/212 5,33, ,33,22 Part 2 - DSUE Received from Other Predeceased Spouse(s) and Used by Decedent BETH R TYLER 1/5/212 2,659,148 2,, 212 Total (for all DSUE amounts applied) 2,, Add amount from Part 1, Column D and Total of Part 2, Column E 7,33,22 91

92 Form 76 (Rev ) PRIOR YEAR FORM Decedent's social security number Estate of: Edward Fleisher SCHEDULE C - Mortgages, Notes, and Cash (For jointly owned property that must be disclosed on Schedule E, see instructions.) Note. If the value of the gross estate, together with the amount of adjusted taxable gifts, is less than the basic exclusion amount and the Form 76 is being filed solely to elect portability of the DSUE amount, consideration should be given as to whether you are required to report the value of assets eligible for the marital or charitable deduction on this schedule. See the instructions and Reg. section T(a)(7)(ii) for more information. If you are not required to report the value of an asset, identify the property but make no entries in the last three columns. Item number Description Alternate valuation date Alternate value Value at date of death 1 Cash under mattress 17,, PRIOR YEAR FORM PRIOR YEAR mmmmm FORM mmmmmmmmmmmmmmmmm Total from continuation schedules (or additional statements) attached to this schedule TOTAL. (Also enter on Part 5 - Recapitulation, page 3, at item 3.) 17,, (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) JSA Schedule C - Page 11 1R

93 Form 76 (Rev ) Decedent's social security number Estate of: Edward Fleisher SCHEDULE J I- Funeral Expenses and Expenses Incurred in Administering Property Subject to Claims Use Schedule PC to make a protective claim for refund due to an expense not currently deductible. For such a claim, report the expense on Schedule J but without a value in the last column. Note. Do not list expenses of administering property not subject to claims on this schedule. To report those expenses, see instructions. If executors' commissions, attorney fees, etc., are claimed and allowed as a deduction for estate tax purposes, they are not allowable as a deduction in computing the taxable income of the estate for federal income tax purposes. They are allowable as an income tax deduction on Form 141, U.S. Income Tax Return for Estates and Trusts, if a waiver is filed to forgo the deduction on Form 76 (see Instructions for Form 141). Are you aware of any actual or potential reimbursement to the estate of any expense claimed as a deduction on this Yes No schedule? mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm If "Yes," attach a statement describing the expense(s) subject to potential reimbursement. (see instructions) Item Description Expense amount Total amount number A. Funeral expenses: 1 Stretch Funeral Home 3, PRIOR YEAR FORM Total from continuation schedules Total funeral expenses mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm I 3, B. Administration expenses: 1 Executors' commissions - amount estimated/agreed upon/paid. (Strike out the words that do not apply.) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 2 Attorney fees - amount estimated/agreed upon/paid. (Strike out the words that do not apply.) mmmmm 3 Accountant fees - amount estimated/agreed upon/paid. (Strike out the words that do not apply.)m mmm 4 Miscellaneous expenses: None PRIOR YEAR FORM Expense amount 4, Total miscellaneous expenses from continuation schedules (or additional statements) attached to this schedule mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm Total miscellaneous expenses mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmi PRIOR mmmmmmmmmmmmmmmmmmmmmmmm YEAR FORM I TOTAL. (Also enter on Part 5 Recapitulation, page 3, at item 14.) 43, (If more space is needed, attach the continuation schedule from the end of this package or additional statements of the same size.) Schedule J - Page 17 JSA 1R

94 Form 76 (Rev ) PRIOR YEAR FORM PRIOR YEAR FORM Decedent's social security number Estate of: Edward Fleisher SCHEDULE P - Credit for Foreign Death Taxes List all foreign countries to which death taxes have been paid and for which a credit is claimed on this return. If a credit is claimed for death taxes paid to more than one foreign country, compute the credit for taxes paid to one country on this sheet and attach a separate copy of Schedule P for each of the other countries. The credit computed on this sheet is for the (Name of death tax or taxes) imposed in (Name of country) Credit is computed under the (Insert title of treaty or statute) Citizenship (nationality) of decedent at time of death (All amounts and values must be entered in United States money.) 1 Total of estate, inheritance, legacy, and succession taxes imposed in the country named above attributable to property situated in that country, subjected to these taxes, and included in the gross estate (as defined by statute) 1 mmmmmm mmmmmmmmmmmmmmmmmmmmmmm 3 Value of property situated in that country, subjected to death taxes imposed in that country, and included in the mmmmmmmmmmmmmmmmmmmmmmmmmmmmm 2 Value of the gross estate (adjusted, if necessary, according to the instructions) 2 gross estate (adjusted, if necessary, according to the instructions) 3 mmmmm 5 Amount of federal estate tax attributable to property specified at item 3. (Divide item 3 by item 2 and multiply the 4 Tax imposed by section 21 reduced by the total credits claimed under sections 21 and 212 (see instructions) 4 result by item 4.) mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 5 6 Credit for death taxes imposed in the country named above (the smaller of item 1 or item 5). Also enter on line 13 of Part 2 - Tax Computation Part 1. Transferor Information mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm SCHEDULE Q - Credit for Tax on Prior Transfers IRS office where estate Name of transferor Social security number Date of death tax return was filed 6 A Betty Alden Cincinnati, OH 5/22/211 B - - C Check here I - - if section 213(f) (special valuation of farm, etc., real property) adjustments to the computation of the credit were made (see instructions). Part 2. Computation of Credit (see instructions) Item 1 Transferee's tax as apportioned (from worksheet, (line 7( line 8) x line 35 for each column) mmmm 2 Transferor's tax (from each column of worksheet, line 2) mmmmmmmmmmmmmmmmmmmmm Transferor A B C 2,343,62 826,27 Total A, B, & C 3 Maximum amount before percentage requirement (for each column, enter amount from line 1 or 2, whichever is smaller)m mmmmmmmmmmmmmm 826,27 4 Percentage allowed (each column) (see instructions) % % % 5 Credit allowable (line 3 x line 4 for each column) 6 TOTAL credit allowable (add columns A, B, and C of Computationm mmmmmmmmmmmmmmmmmm line 5). Enter here and on line 14 of Part 2 - Tax 1 826,27 PRIOR YEAR FORM 826,27 JSA 1R Schedules P and Q - Page 22 94

95 Part I Worksheet for Schedule Q - Credit for Tax on Prior Transfers Transferor's tax on prior transfers Item 1. Gross value of prior transfer to this transfereem m 2. Death taxes payable from prior transferm mmmm 1,32, PRIOR 3. Encumbrances allocable YEAR to prior transfer mmmm FORM 4. Obligations allocable to prior transferm mmmmm 5. Marital deduction applicable to line 1 above, as shown on transferor's Form 76m mmmmmm 6. TOTAL. Add lines 2, 3, 4, and 5 mmmmmmmm 7. Net value of transfers. Subtract line 6 from line 1 mmmmmmmmmmmmmmm 8. Net value of transfers. Add columns A, B, and C of line 7 mmmmmmmmmmmmmm 9. Transferor's taxable estatemmmmmmmmmmm 1. Federal estate tax paid mmmmmmmmmmmm 11. State death taxes paid mmmmmmmmmmmm 12. Foreign death taxes paid mmmmmmmmmmm 13. Other death taxes paid mmmmmmmmmmmm 14. TOTAL taxes paid. Add lines 1, 11, 12, and Value of transferor's estate. Subtract line 14 from line 9m mmmmmmmmmmmmmm mmmmmmmmmmmmmmmmmmmm 16. Net federal estate tax paid on transferor's estate 17. Credit for gift tax paid on transferor's estate with respect to pre-1977 gifts (section 212)m m 18. Credit allowed transferor's estate for tax on prior transfers from prior transferor(s) who died within 1 years before death of decedent mmm 19. Tax on transferor's estate. Add lines 16, 17, and Transferor's tax on prior transfers ((line 7 ( line 15) x line 19 of respective estates)m mmmm Transferee's tax on prior transfers Part II Transferor (From Schedule Q) PRIOR YEAR FORM 826,27 mmmmmmmmmmmmmmm Item 21. Transferee's actual tax before allowance of credit for prior transfers (see instructions) Total gross estate of transferee from line 1 of the Tax Computation, page 1, Form 76 mmmmmmmmmmmmmm Net value of all transfers from line 8 of this worksheetm mmmmmmmmmmmmmmmmmmmmmmmmmmmmm Transferee's reduced gross estate. Subtract line 23 from line 22 mmmmmmmmmmmmmmmmmmmmmmmmm 25. Total debts and deductions (not including marital and charitable deductions) (line 3b of Part 2 - Tax Computation, page 1 and items 18, 19, and 2 of the Recapitulation, page 3, Form 76) mmmmmmmmmmmmmmmmmmmmmm Marital deduction from item 21, Recapitulation, page 3, Form 76 mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 27. Charitable bequests from item 22, Recapitulation, page 3, Form 76 mmmmmmm (see instructions) Charitable deduction proportion ( [ line 23 (line 22 - line 25) ] x line 27) 28 ( mmmmm Reduced charitable deduction. Subtract line 28 from line 27 mmmmmmmmmmm Transferee's deduction as adjusted. Add lines 25, 26, and 29 mmmmmmmmmmmmmmmmmmmmmmmmmm (a) Transferee's reduced taxable estate. Subtract line 3 from line 24 mmmmmmmmmmmmmmmmmmmmmm 31(a) (b) Adjusted taxable gifts mmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmmm 31(b) (c) Total reduced taxable estate. Add lines 31(a) and 31(b)m mmmmmmmmmmmmmmmmmmmmmmmmmm 31(c) 32. Tentative tax on reduced taxable estate mmmmmmmmmmmmmmmmmmmmm 32 4,879, (a) Post-1976 gift taxes paid mmmmmmmmmmmm 33(a) (b) Unified credit (applicable credit amount) mmmmm 33(b) 4,859,81 (c) Section 212 gift tax credit mmmmmmmmmmm 33(c) (d) Section 214 foreign death tax credit mmmmmm (e) Total credits. Add lines 33(a) through 33(d) 34. mmmmmmmmmmmmmmmmmmmmmmm 35. Transferee's tax on prior transfers. Subtract line 34 from line 21 mmmmmmmmmmmmmmmmmmmmmmmmm Total for all transfers (line 8 only) Amount 2,364,293 17,, 5,859,49 11,14,951 33(d) mmmmmmmmmmmmmmmmm 33(e) 4,859,81 PRIOR YEAR FORM Net tax on reduced taxable estate. Subtract line 33(e) from line JSA 1R A B C 7,292, ,876 1,433,876 5,859,49 5,859,49 7,161,49 826,27 475,973 1,32, 5,859,49 826,27 826,27 5,859,49 5,859,49 86,65 5,859,49 86,65 1,334,886 2,, 12,334,886 2,673 2,343,62 95

96 Estate of: Edward Fleisher Worksheet TG - Taxable Gifts Reconciliation Total taxable gifts made before 1977 Line 4 - Taxable gifts made after 1976 Calendar Total Taxable amount Amount qualifying Gift tax Gift tax year or taxable gifts included in as special paid by paid by quarter for period gross estate treatment gifts decedent spouse (a) (b) (c) (d) (e) (f) ,, Totals 2,, 1. Taxable gifts made after 1976 (from column b) 2,, 2. Taxable gifts made after 1976 included in gross estate (from column c) 3. Taxable gifts made after 1976 that qualify for "special treatment" (from column d) 4. Add lines 2 and 3 5. Adjusted taxable gifts 2,, 96

97 Estate of: Edward Fleisher Worksheet TG - Taxable Gifts Reconciliation Line 7 - Gift tax on gifts made after 1976 (a) (b) (c) (d) (e) (f) (g) (h) Cumulative DSUE from Predeceased Cumulative Tax Based Tax on Spouse(s) Taxable Taxable Taxable Gifts on 213 Cumulative Tax on Gifts Applied to Gifts for Gifts for Including Rates for Gifts Including for Current Current & Period Current Period Prior Periods Current Period Prior Gifts Current Period Period Prior Gifts Pre ,, 2,, 745,8 745,8 2,, (i) (j) (k) (l) (m) (n) (o) Basic Maximum Applicable Exclusion Applicable Credit Amount Available Tax Amount Credit based Allowable Credit Payable for Current on amount in Prior in Current Credit for Current Period Total in Column J Periods Period Allowable Period Pre ,12, 7,12, 2,793,8 2,793,8 745,8 1. Total gift taxes payable on gifts made after 1976 (add amounts in column (o)) 2. Gift tax paid by the decedent on gifts that qualify for "special treatment" (from Line 4 worksheet, column e) 3. Subtract line 2 from line 1 4. Gift tax paid by the decedent's spouse on split gifts (from Line 4 worksheet, column f) 5. Add lines 3 and 4 97