- 2 - death, and all Rule references are to the Tax Court Rules of Practice and Procedure. After settlement of some issues, the issue remaining for decision is whether predeath transfers of decedent’s property with a value of $144,400 and made for no consideration were revocable under Connecticut law and includable in decedent’s gross estate under section 2038(a)(1). Background This case was submitted fully stipulated under Rule 122. On June 1, 1996, Mary Catherine IX Gaynor, decedent, died a resident of Branford, Connecticut. On October 7, 1986, approximately 10 years prior to decedent’s death, decedent executed a general power of attorney (POA) under the Connecticut Statutory Short Form Power of Attorney Act (the Act), Conn. Gen. Stat. Ann. secs. 1-42 to 1-56 (West 2000). In the POA, decedent appointed an attorney and decedent’s son, Gerald Gaynor, as attorneys-in-fact to act in decedent’s stead. The POA consisted of a standard form POA under Connecticut law and explicitly authorized decedent’s attorneys-in-fact to act in decedent’s stead with respect to decedent’s ownership interests in real estate, chattels and goods, stocks and bonds, banking, insurance, claims and litigation, personal relationshipsPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011