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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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