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Applicable Federal Rates for 1985

— Short Term Rates for 1985 —

Month	Annual	Semiann.	Quarterly	Monthly
Jan-85*	9.79%	9.56%	9.45%	9.37%
Feb-85*	9.79%	9.56%	9.45%	9.37%
Mar-85*	9.77%	9.54%	9.43%	9.36%
Apr-85*	10.37%	10.11%	9.99%	9.90%
May-85*	10.36%	10.10%	9.98%	9.89%
Jun-85*	9.58%	9.36%	9.25%	9.18%
Jul-85	8.69%	8.51%	8.42%	8.36%
Aug-85	8.41%	8.24%	8.16%	8.10%
Sep-85	8.74%	8.56%	8.47%	8.41%
Oct-85	8.71%	8.53%	8.44%	8.38%
Nov-85	8.68%	8.50%	8.41%	8.35%
Dec-85	8.59%	8.41%	8.32%	8.27%

— Mid Term Rates for 1985 —

Month	Annual	Semiann.	Quarterly	Monthly
Jan-85*	11.48%	11.71%	11.02%	10.92%
Feb-85*	11.48%	11.71%	11.02%	10.92%
Mar-85*	11.30%	11.00%	10.85%	10.76%
Apr-85*	11.84%	11.51%	11.35%	11.24%
May-85*	11.83%	11.50%	11.34%	11.23%
Jun-85*	11.18%	10.88%	10.74%	10.64%
Jul-85	10.23%	9.98%	9.86%	9.78%
Aug-85	10.02%	9.78%	9.66%	9.59%
Sep-85	10.31%	10.06%	9.94%	9.86%
Oct-85	10.17%	9.92%	9.80%	9.72%
Nov-85	10.21%	9.96%	9.84%	9.76%
Dec-85	9.91%	9.68%	9.57%	9.49%

— Long Term Rates for 1985 —

Month	Annual	Semiann.	Quarterly	Monthly
Jan-85*	11.92%	11.58%	11.42%	11.31%
Feb-85*	11.92%	11.58%	11.42%	11.31%
Mar-85*	11.72%	11.40%	11.24%	11.14%
Apr-85*	12.22%	11.87%	11.70%	11.59%
May-85*	12.21%	11.86%	11.69%	11.58%
Jun-85*	11.74%	11.41%	11.25%	11.15%
Jul-85	10.90%	10.62%	10.48%	10.39%
Aug-85	10.72%	10.45%	10.32%	10.23%
Sep-85	10.98%	10.69%	10.55%	10.46%
Oct-85	10.83%	10.55%	10.41%	10.33%
Nov-85	10.91%	10.63%	10.49%	10.40%
Dec-85	10.60%	10.33%	10.20%	10.11%

* Note: As originally enacted as part of the Tax Reform Act of 1984 (P.L. 98-369), section 1274 provided for applicable federal rates to be determined every six months. This was amended by the Imputed Interest Rules Amendments Act of 1985 (P.L. No. 99-121) to require that rates be redetermined every month. In accordance with section 1274 as originally enacted, the IRS published applicable federal rates for 1984 and the first half of 1985 in Rev. Rul. 84-163, 1984-2 C.B. 179, and those rates for the first half of 1985 were as follows:

— Rates Originally Published for January 1, 1985 to June 30, 1985 —

Month	Annual	Semiann.	Quarterly	Monthly
Short-Term	12.37%	12.01%	11.83%	11.72%
Mid-Term	13.37%	12.95%	12.75%	12.61%
Long-Term	13.43%	13.01%	12.81%	12.67%

Applicable Federal Rates for 1984

Note: As originally enacted as part of the Tax Reform Act of 1984 (P.L. 98-369), section 1274 provided for applicable federal rates to be determined every six months. This was amended by the Imputed Interest Rules Amendments Act of 1985 (P.L. No. 99-121) to require that rates be redetermined every month. In accordance with section 1274 as originally enacted, the IRS published applicable federal rates for 1984 and the first half of 1985 in Rev. Rul. 84-163, 1984-2 C.B. 179, and those rates for 1984 were as follows:

— Short Term Rates for 1984 —

Month	Annual	Semiann.	Quarterly	Monthly
Jan-Jun	10.25%	10.00%	9.88%	9.80%
Jul-Dec	10.78%	10.50%	10.37%	10.28%

— Mid Term Rates for 1984 —

Month	Annual	Semiann.	Quarterly	Monthly
Jan-Jun	11.18%	10.88%	10.74%	10.64%
Jul-Dec	11.97%	11.63%	11.47%	11.36%

— Long Term Rates for 1984 —

Month	Annual	Semiann.	Quarterly	Monthly
Jan-Jun	11.57%	11.25%	11.10%	11.00%
Jul-Dec	12.23%	11.88%	11.71%	11.60%

Interest on Underpayment of Pennsylvania Taxes

(Current through December 2025)

Under sections 806 and 806.1 of the Fiscal Code (72 P.S. §§ 806 and 806.1), all underpayments of tax which became due and payable to the Commonwealth of Pennsylvania on or after January 1, 1982, bear interest at the same rate established under section 6621(a)(2) of the Internal Revenue Code. However, the Pennsylvania interest is simple interest (and not compounded like federal interest) and the Pennsylvania rates are adjusted annually, and not quarterly.

These same rates apply to overpayments of tax under Article III of the Tax Reform Code of 1971, but all other overpayments of tax bear interest at a rate that is two percentage points lower.

The following is a table of the rates that have applied since January 1, 1982, expressed both as an annual rate and as a daily factor. To calculate interest for X days, multiply the daily factor by X and the tax underpaid. (See also, 61 Pa.Code 4.2.)

Year	Underpayment Annual Rate	Underpayment Daily Factor	Authority
1982	20%	0.000548
1983	16%	0.000438
1984	11%	0.000301
1985	13%	0.000356
1986	10%	0.000274
1987	9%	0.000247	16 Pa.B. 4908
1988	11%	0.000301	17 Pa.B. 5286
1989	11%	0.000301	18 Pa.B. 5680
1990	11%	0.000301	19 Pa.B. 5081
1991	11%	0.000301	20 Pa.B. 5870
1992	9%	0.000247	21 Pa.B. 6012
1993	7%	0.000192	22 Pa.B. 6142
1994	7%	0.000192	24 Pa.B. 81
1995	9%	0.000247	24 Pa.B. 6486
1996	9%	0.000247	25 Pa.B. 5788
1997	9%	0.000247	26 Pa.B. 6224
1998	9%	0.000247	27 Pa.B. 6866
1999	7%	0.000192	28 Pa.B. 6351
2000	8%	0.000218	29 Pa.B. 6377
2001	9%	0.000247	30 Pa.B. 6494
2002	6%	0.000164	31 Pa.B. 6990
2003	5%	0.000137	32 Pa.B. 6220
2004	4%	0.000110	34 Pa.B 448
2005	5%	0.000137	35 Pa.B 78
2006	7%	0.000192	35 Pa.B 7067
2007	8%	0.000218	36 Pa.B 8021
2008	7%	0.000192	37 Pa.B 6970
2009	5%	0.000137	39 Pa.B 103
2010	4%	0.000110	39 Pa.B. 7256
2011	3%	0.000082	40 Pa.B. 7443
2012	3%	0.000082	41 Pa.B. 7041
2013	3%	0.000082	42 Pa.B. 7775
2014	3%	0.000082	43 Pa.B 7602
2015	3%	0.000082	44 Pa.B 8063
2016	3%	0.000082	46 Pa.B. 297
2017	4%	0.000110	46 Pa.B. 8108
2018	4%	0.000110	47 Pa.B. 7789
2019	6%	0.000164	48 Pa.B. 7995
2020	5%	0.000137	49 Pa.B. 7361
2021	3%	0.000082	50 Pa.B. 7361
2022	3%	0.000082	51 Pa.B. 8028
2023	7%	0.000192	52 Pa.B. 7981
2024	8%	0.000218	53 Pa.B. 8006
2025	7%	0.000192	54 Pa.B. 8464

No Undue Influence in Beneficiary Designation

Dead Man’s Act applies to bar testimony of beneficiaries claiming interest in annuity contract, and was not waived by allegations by executor that beneficiaries had used undue influence over the decedent. Applying principles similar to those that apply to wills, the court found that there was a presumption of validity in the beneficiary designation, that the burden was on the executor to show elements of undue influence, and that the executor failed to introduce evidence of weakened intellect. Jackson Nat’l Life Insur. V. John Heyser et al., 4 Fid.Rep.3d 29 (U.S.D.C. E.D. Pa 2014).

Mother of Claimant not Barred by Dead Man’s Act

In dispute with estate over ownership of watch, the person in possession of the watch cannot testify as to the alleged gift because of the Dead Man’s Act, but the mother of the alleged donee can testify. Jamack Estate v Reis, 4 Fid.Rep.3d 25 (Lycoming Co. C.P. 201).

Judicial and Equitable Estoppel

Having taken a position in settlement of wrongful death and survival action as to proper division of proceeds, and having paid inheritance tax based on that position, removed executor is estopped from changing her position as to division of estate because of judicial and equitable estoppel. Neaconia Estate, 4 Fid. Rep. 3d 1 (O.C. Lehigh 2013) (Opinion by Reibman, J.)

Erroneous Distributions and Dilatory Conduct

Estate distribution was erroneous because share of charitable beneficiary was reduced by inheritance tax paid, and noncharitable beneficiaries were required to return the excess distributions in accordance with the indemnification agreements they signed at the time of the initial distributions. Executor commissions and legal fees were both reduced, and legal fees were awarded in favor of the Attorney General, and against counsel to the executor, for excess time expended by the Attorney General due the dilatory conduct of counsel. Shilling Estate, 4 Fid.Rep.3d 8 (Adams Co. O.C. 2014)

Applicable Federal Rates for 2013

← Previous Year | Current Year | Following Year →

— Short Term Rates for 2013 —

Month	Annual	Semiann.	Quarterly	Monthly
Jan-13	0.21%	0.21%	0.21%	0.21%
Feb-13	0.21%	0.21%	0.21%	0.21%
Mar-13	0.22%	0.22%	0.22%	0.22%
Apr-13	0.22%	0.22%	0.22%	0.22%
May-13	0.20%	0.20%	0.20%	0.20%
Jun-13	0.18%	0.18%	0.18%	0.18%
Jul-13	0.23%	0.23%	0.23%	0.23%
Aug-13	0.28%	0.28%	0.28%	0.28%
Sep-13	0.25%	0.25%	0.25%	0.25%
Oct-13	0.32%	0.32%	0.32%	0.32%
Nov-13	0.27%	0.27%	0.27%	0.27%
Dec-13	0.25%	0.25%	0.25%	0.25%

— Mid Term Rates for 2013 —

Month	Annual	Semiann.	Quarterly	Monthly
Jan-13	0.87%	0.87%	0.87%	0.87%
Feb-13	1.01%	1.01%	1.01%	1.01%
Mar-13	1.09%	1.09%	1.09%	1.09%
Apr-13	1.09%	1.09%	1.09%	1.09%
May-13	1.00%	1.00%	1.00%	1.00%
Jun-13	0.95%	0.95%	0.95%	0.95%
Jul-13	1.21%	1.21%	1.21%	1.21%
Aug-13	1.63%	1.62%	1.62%	1.62%
Sep-13	1.66%	1.65%	1.65%	1.64%
Oct-13	1.93%	1.92%	1.92%	1.91%
Nov-13	1.73%	1.72%	1.72%	1.71%
Dec-13	1.65%	1.64%	1.64%	1.63%

— Long Term Rates for 2013 —

Month	Annual	Semiann.	Quarterly	Monthly
Jan-13	2.31%	2.30%	2.29%	2.29%
Feb-13	2.52%	2.50%	2.49%	2.49%
Mar-13	2.66%	2.64%	2.63%	2.63%
Apr-13	2.70%	2.68%	2.67%	2.67%
May-13	2.60%	2.58%	2.57%	2.57%
Jun-13	2.47%	2.45%	2.44%	2.44%
Jul-13	2.80%	2.78%	2.77%	2.76%
Aug-13	3.16%	3.14%	3.13%	3.12%
Sep-13	3.28%	3.25%	3.24%	3.23%
Oct-13	3.50%	3.47%	3.46%	3.45%
Nov-13	3.37%	3.34%	3.33%	3.32%
Dec-13	3.32%	3.29%	3.28%	3.27%

Disclaimers and Medicaid

A disclaimer is a transfer without value that can affect eligibility for Medical Assistance – Long Term Care benefits. Schell v. Dept. of Public Welfare, 80 A.3d 844, 203 C.D. 2013 (Pa. Cmwlth. 12/4/13).

Indirect Criminal Contempt of Orphans’ Court Order

After Orphans’ Court ordered son of alleged incapacitated person (mother) not to visit his mother at her nursing home without siblings’ supervision, (because he had previously manipulated her, blocked access to her, moved her out of state, and filed bankruptcy actions on her behalf), Orphans’ court held that the son committed indirect criminal contempt, when the son went to visit his mother on the day following the court order without his siblings’ supervision, because the order was clear, the son had notice of the order, the son’s actions were volitional, and the son acted with wrongful intent. Matter of Angelina Mazza, 3 Fid. Rep. 3d 427 (O.C. Chester 2013) (Opinion by Tunnell, J.)