Estate of Suzanne C. Pruitt - Page 28




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         specific and general powers were transfers for value.”  Id. at               
         901.                                                                         
              The decision of the Court of Appeals for the Fourth Circuit             
         in Estate of Casey is distinguishable from the instant case.                 
         Although the power of attorney in Estate of Casey authorized the             
         decedent’s attorney-in-fact “To lease, sell, grant, convey,                  
         assign, transfer, mortgage and set over” decedent’s property,                
         such actions were required to be taken “for such consideration as            
         he may deem advantageous”.  Id. at 896.   In addition, the case              
         record as summarized in the opinions of this Court, see Estate of            
         Casey v. Commissioner, T.C. Memo. 1989-511, and the Court of                 
         Appeals for the Fourth Circuit does not disclose with the same               
         clarity as in the present case what understanding, if any,                   
         decedent had regarding the scope of authority conferred by the               
         power of attorney that she signed.  In contrast, the powers of               
         attorney at issue here do not limit the authority of the                     
         attorney-in-fact to conveyances for consideration as she deems               
         advantageous, and the record in the instant case contains                    
         evidence from which we can ascertain decedent’s intention to                 
         confer broad authority on her attorney-in-fact.                              













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