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the partially integrated agreement. Restatement
(Second) of Contracts � 213(1) (1979). * * *
[Abercrombie v. Hayden Corp., 883 P.2d at 850; fn. ref.
omitted.]
“Under Oregon law, a power of attorney creates an agency
relationship. * * * Therefore, the authorities and duties of
an attorney in fact are governed by the principles of agency.”
Wilkinson v. Commissioner, T.C. Memo. 1993-336; see also Scott v.
Hall, 163 P.2d 517, 518 (Or. 1945) (“Attorneys in fact created by
formal letters of attorney are merely special kinds of agents
* * * and in construing such letters or powers and determining
their effect the principles of the law of agency apply.”); Ho v.
Presbyterian Church, 840 P.2d 1340-1343 (Or. Ct. App. 1992).
Petitioner argues that Oregon’s parol evidence rule does not
apply in cases like this where a litigant who is not a party to
the power of attorney is attempting to use the rule to exclude
evidence regarding the intent of the principal and the
circumstances surrounding the execution of the power of attorney.
We need not decide whether a litigant who is not a party to
the power of attorney may invoke Oregon’s parol evidence rule,
codified in Or. Rev. Stat. sec. 41.740 (1999). Although it is
well established under Oregon law that the authority conferred by
a power of attorney cannot be enlarged by parol evidence, see
United States Natl. Bank v. Herron, 144 P. 661, 663-664 (Or.
1914) (interpreting a limited power of attorney); Wade v.
Northup, 140 P. 451, 457 (Or. 1914) (interpreting a general power
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