Case Involving Independent Executors Resignation
In Ullrich v. Estate of Anderson, 740 S.W.2d 481 (Tex. App.--Houston [1st Dist.] 1987, no writ), although there was originally an independent administration of the estate, the independent executors had resigned and successor administrators had been appointed by the probate court and operated under the supervision of that court.
It was in that context that the appellate court explicated that "claims by representatives that accrued directly against the testator or intestate are to be acted upon by the court pursuant to section 317(c)." Id. at 483.
The Ullrich court was not considering an independent executorship.