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gifts. Estate of Pruitt v. Commissioner, supra; Estate of
Bronston v. Commissioner, supra.
Even if our interpretation of Connecticut law is mistaken
and the Supreme Court of Connecticut would allow under general
POAs gifts to be made by attorneys-in-fact, the evidence in the
instant case does not indicate that decedent herein had
established a pattern of gift giving or that decedent intended to
give a POA that included the power to transfer decedent’s
property without consideration.
We conclude that prior to her death decedent retained the
power under Connecticut law to revoke the transfers of the
property with a value of $144,400. Under section 2038(a)(1), the
value of that property is to be included in decedent’s estate.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011