- 20 - 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 notPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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