Estate of Suzanne C. Pruitt - Page 23




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         tax liabilities of her estate; the testimony of decedent’s                   
         daughter, Ms. Thompson, and decedent’s attorney, Mr. Walker; and             
         decedent’s last will and testament.  We review this evidence for             
         what it shows, if anything, about decedent’s intent regarding the            
         interpretation of the powers of attorney in this case.                       
              Beginning in 1980 and continuing annually through 1992,                 
         decedent made gifts to the natural objects of her bounty.                    
         Decedent gave her daughters annual gifts in amounts that                     
         increased over time.  In 1987, decedent expanded her gifting                 
         program to include her sons-in-law and her grandchildren.  When              
         decedent executed the first of her three powers of attorney in               
         1987, the gifting program was well established and steadily                  
         growing, and she already had made her annual gifts for 1987.  The            
         power of attorney was executed in connection with estate planning            
         by decedent and her husband which was designed to minimize, to               
         the fullest extent possible, the estate and gift tax liability of            
         their estates and to maximize the assets passing to their family.            



              13(...continued)                                                        
                    We realize we are getting older and do not need so                
               much so thought it would be nice to share now.                         
                    Just remember, we love you lots and are glad you                  
               were born to us.                                                       
                                                  Lots of love –                      
                                                  Your Daddy + Mom                    







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