Voiding an act of self-dealing by an executor, and not surcharge, is a proper remedy when the recipient of the transfer of estate property is the executor’s wife and she is complicit, and the transfer cannot be justified as an exchange for a claim against the estate when the claim represents a conflict of interest and was for less than the appraised value of the property. DiMatteo Estate, 1 Fid.Rep.4th 97 (Allegheny O.C. 2022), aff’d 362 WDA 2022 (Pa. Super. 1/27/2023) (non-precedential).

[For a related decision in the same case, see “Conveyance of Real Estate Set Aside for Self-Dealing.”]