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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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