Kowalski v. Rosenbaum

MORRIS, Judge.

Lorraine Kowalski appeals an order confirming a special master's report in the probate proceedings of her deceased husband's estate. We affirm the order confirming the special master's findings and conclusions, but we write to discuss Kowalski's claim that certain money was not subject to probate because it was held by her and the decedent as tenants by the entireties.

Kowalski and the decedent were still married but had been separated for approximately sixteen years at the time of the decedent's death in 2015. In a will executed prior to his death, the decedent left the majority…