18 May 2015

Estate: McKeown v. Small & Geary

Brother was set against sisters in a dispute over who carried investment losses incurred in their parents’ estates.  Emotions were coloured by their mother’s actions in the last year of her life disinheriting her son.
The High Court ordered two sisters to pay $93,126 plus accrued interest to their brother James McKeown as compensation for an incorrect division of their father’s estate after investment losses in South Canterbury Finance and Dominion Finance were wrongly apportioned.
Evidence was given that their parents signed mutual wills in 2002 recording that their three children would ultimately share their estates equally.  Their father died first.  His widow died six years later.  In the interim she changed the terms of her will with the effect of disinheriting son James.  In an accompanying note she explained her reason: James had received “help” when purchasing the family farm in the Totara Valley near Timaru while her daughters had not received similar benefits. 
James did not inherit from his mother’s estate or receive any capital from a family trust set up by his parents.  He did not challenge these outcomes but did take issue with the way investment losses had been calculated when valuing his father’s estate.  Along with his two sisters, he received a one third share of his father’s estate.  These funds did not become available until after his mother’s death in 2008.  James claimed his father’s estate was valued at $944,300; his sisters said it was $661,500 – the difference being who bore investments losses in the six years between each parent’s death.  Rules governing business partnerships were applied. 
The court was told their parents had been in a farming partnership called PS & HM McKeown.  While in partnership, they placed money with South Canterbury Finance and Dominion Finance.  Investors in these companies were later to suffer substantial losses. Funds for these investments came from the farming partnership.  Partnership law states that assets purchased with partnership money belong to the partnership, unless partners agree otherwise.  Partnership law also states that a partnership ends automatically on the death of a partner unless the partnership agreement provides otherwise.  Justice Gendall ruled that on death the father’s estate did continue in partnership with his widow because his will specifically authorised his trustees to do so.  This meant the failing investments continued to be held by the partnership since it continued beyond his death.  As a result, investment losses fell on the partnership and ultimately on all three of the children who inherited.
Tax advisers acting for the estate had contributed to the confusion by assuming the South Canterbury and Dominion Finance investments had been the father’s personal investments.  This led to the investment losses being incorrectly allocated solely to the father’s estate, directly impacting on James’ limited inheritance.
Justice Gendall was critical of accounting records maintained for the partnership, especially given the oddity that the father was recorded as receiving a salary for some time after his death.
McKeown v. Small & Geary – High Court (18.05.15)

15.049