An accounting is the fiduciary's formal report to the court and beneficiaries. It is the primary mechanism of accountability in Pennsylvania fiduciary law and the foundation for the court's decree of distribution.
Components of a Formal Accounting (Pa.O.C. Rule 2.1)
Accounts must conform to the Model Accounts in the Rules Appendix and include:
- A cover page
- A summary page with page references
- Separate schedules for receipts, gains/losses on sales, disbursements, distributions, investments, changes in holdings
- Signature and verification pages signed by all accountants, verified by at least one
- The verification of a personal representative's account must state that the Grant of Letters and first complete advertisement occurred more than four months before the filing of the account, unless the court has directed the personal representative to file sooner
Principal and income must be accounted for separately. All dates, sources of receipts, recipients of disbursements, and purposes must be stated.
Bucks County Audit Procedure
The Clerk of the Orphans' Court (not the attorney) is responsible for advertising notice of accounts filed and the time and place of the audit call (20 Pa.C.S. § 745(a)). But the accountant must separately give written notice of the filing and audit date to every unpaid claimant and every person known to have an interest in the estate (Pa.O.C. Rule 2.5).
At the audit, one of three things happens:
- Contested: The court fixes a conference date and mails notice to all parties who have entered an appearance
- Uncontested with a question: Counsel presents the issue and proposed solution at the call of the list
- Uncontested: The account proceeds to confirmation and distribution
The Petition for Adjudication
This is the most important paper presented at audit. It is prepared using the specific forms on the Bucks County Register of Wills/Clerk website (different forms for decedent 's estates, trusts, and guardianships). The petition forms the basis for the court's adjudication or decree of distribution and must provide all factual information necessary for a proper award. The petition must:
- Include either a certification of payment from the Register or a copy of the notice of appraisement from the Department of Revenue
- Attach the governing instrument (will, trust agreement) if the prayer for distribution is based on a written instrument
- Be signed and verified by at least one of the accountants, with counsel for the accountant also signing (Pa.O.C. Rule 2.4(d), (e))
- Ask the court to direct a schedule of distribution if principal will be distributed in kind
Filing Checklist: From the Clerk of Orphans' Court
Audit & Adjudication Checklist
- Account coversheet/summary page, signed by accountant or attorney
- Petition for Adjudication & Statement of Proposed Distribution
- Photocopy of will and codicils (if applicable)
- Photocopy of Letters Testamentary /Administration or Short Certificate
- Proof of advertisement of letters
- Photocopy of inventory
- Entry of appearance
- Certificate of service
- Inheritance tax receipts
- Agreement of compromise and settlement (if applicable)
- Agreement regarding accountant's compensation (if applicable)
- Certificate of Compliance, Confidential Information Form, and/or Confidential Document Form
Objections to Accountings (Pa.O.C. Rule 2.7)
Objections must be filed on or before the time and date of the audit, with a copy sent to the accountant's counsel and each interested party. Each objection must be specific as to description and amount, raise one issue of law or fact, and briefly state the supporting reasons. Preliminary objections to objections are limited to lack of jurisdiction over the subject matter and lack of standing (Rule 2.8(b)).
Specialized Accounting Issues: Key Authority
In re Estate of Bates , 28 Pa. D. & C.5th 19 (Monroe Cty. O.C. 2013). Addresses the Orphans' Court treatment of casualty insurance proceeds tied to specifically devised property. Under 20 Pa.C.S. § 2514(18)(iii), when fire or casualty insurance proceeds on specifically devised property remain unpaid at the testator 's death, does the beneficiary receive the insurance proceeds as a substitute under 20 Pa.C.S. § 2514 (the ademption exception)? Bates applies this rule at the county level. The controlling appellate authority is In re Estate of Sagel, 901 A.2d 538 (Pa. Super. 2006) (2006 PA Super 134), which holds that a specific devisee is entitled to unpaid casualty insurance proceeds in lieu of the destroyed property. If you are handling an estate where devised property was damaged or destroyed and insurance was paid, Bates is persuasive but not binding (it is a county Court of Common Pleas D&C opinion), while Sagel is binding Superior Court precedent.
Styer v. Hugo , 619 A.2d 347 (Pa. Super. 1993), aff'd , 637 A.2d 276 (Pa. 1994). The clean three-part test for unjust enrichment in Pennsylvania: (1) the plaintiff conferred a benefit on the defendant, (2) the defendant appreciated the benefit, and (3) acceptance and retention of the benefit under the circumstances would be inequitable without payment. This arises in estate and fiduciary contexts when a person provided care, services, or financial support to a decedent expecting compensation that the estate refuses to honor. Styer is the go-to citation for the elements. See also SJW Home Ass'n v. Georgine's Knights, Inc. , No. 2380 EDA 2021 (Pa. Super. Oct. 12, 2022) (non-precedential memorandum affirming judgment for a tenant in a quiet title action and against the lessor in its possession and ejectment action. Unjust enrichment appears only as a conditional cross-appeal issue the tenant raised in case the lease were declared invalid, so the case is not authority on unjust enrichment. Must be identified as non-precedential under Pa. I.O.P. § 65.37 and cited only for persuasive value).
Legal and factual content on this page was last verified: Aug. 2026. If you are reading this significantly after that date, confirm key provisions with current statute text or contact our office.
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