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and affairs, military pensions, records, reports and statements,
and “all other matters”.
The POA did not explicitly authorize decedent’s attorneys-
in-fact to make gifts of decedent’s property.
Under the Act, attorneys-in-fact are not explicitly
authorized to make, or prohibited from making, gifts of a
principal’s property.
Section 1-55 of the Act provides that the words “all other
matters” in a POA indicate that the principal authorized “the
agent to act as an alter ego of the principal with respect to any
matters and affairs not enumerated in sections 1-44 to 1-54a,
inclusive, and which the principal can do through an agent.”
In 1995 and 1996, decedent’s attorneys-in-fact made for no
consideration transfers of decedent’s property with a value of
$144,400. The evidence does not indicate to whom the transfers
were made.
As stated, on June 1, 1996, decedent died.
On February 28, 1997, decedent’s Federal estate tax return
was filed by the administrator of the estate, a resident of
Connecticut. On the return, the $144,400 value of the
transferred property was not included in decedent’s gross estate.
Respondent determined that the above transfers of decedent’s
property constituted revocable transfers under Connecticut law
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Last modified: May 25, 2011