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HOFFMAN v. CONNELL

No. A085214.

87 Cal.Rptr.2d 272 (1999)

73 Cal.App.4th 1194

Paul HOFFMAN, as Co-executor, etc., et al., Plaintiffs and Appellants, v. Kathleen CONNELL, as Controller, etc., Defendant and Respondent.

Court of Appeals of California, First District, Division Five.

July 2, 1999.

Attorney(s) appearing for the Case

Kirt F. Zeigler, Daniel Evans Post, Anderson Zeigler Disharoon Gallagher & Gray, Santa Rosa, Counsel for plaintiffs and appellants.

Geoffrey F. Margolis, Richard J. Chivaro, Sacramento, Office of the State Controller, Counsel for defendant and respondent.

JONES, P.J.

The executors of the estate of Constance T. Cummings contend the trial court erred when it ruled they were obligated to pay California estate tax on property which Ms. Cummings did not own. We agree and will reverse the judgment entered by the trial court.

I. FACTUAL AND PROCEDURAL BACKGROUND

Constance T. Cummings (Connie) was married to Robert S. Cummings (Robert) who was a resident of St. Thomas, the United States Virgin Islands. It...

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