Estate of Suzanne C. Pruitt - Page 20




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          for less than an adequate and full consideration in money or                
          money’s worth, then the amount by which the value of the property           
          exceeded the value of the consideration shall be deemed a gift”).           
          Ms. Thompson was authorized by the terms of the March 12, 1992,             
          No. 2 power not only to sell, mortgage, and pledge decedent’s               
          property, but also to convey decedent’s property.  “Convey” is              
          defined in Black’s Law Dictionary 301 (5th ed. 1979) as follows:            
               To transfer or deliver to another.  To pass or transmit                
               the title to property from one to another.  To transfer                
               property or the title to property by deed, bill of                     
               sale, or instrument under seal.  * * *                                 
          The authority to convey without any qualification of that                   
          authority is broad enough to permit property conveyances for no             
          consideration.  Even if the word “convey” is interpreted to mean            
          transfer for consideration, the March 12, 1992, No. 2 power                 
          broadly authorized Ms. Thompson to deal with decedent’s property            
          “in any other manner” and was not necessarily restricted to                 
          transactions for consideration.                                             
               In other cases where the applicable State law required us to           
          ascertain the decedent’s intent in interpreting a generally                 
          worded power of attorney, we have applied a similar analysis.               
          For example, in Estate of Bronston v. Commissioner, T.C. Memo.              
          1988-510, we examined a power of attorney which granted the                 
          attorney-in-fact the authority to convey property without                   
          restriction to determine if the power to make gifts could be                
          inferred under New Jersey law.  The power of attorney did not               





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