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(b) An undivided one-third interest shall be
credited to the capital account of the Trust
Company of Oklahoma, Trustee of the Michael Gore
Irrevocable Trust; and
(c) An undivided one-third interest shall be
credited to the capital account of the Trust
Company of Oklahoma, Trustee of the Pamela M.
Powell Irrevocable Trust.
I hereby authorized [sic] and empower Pamela M.
Powell as my attorney-in-fact with all those powers
granted to her by that certain Durable Power of
Attorney dated December 23, 1996, to act in my behalf
for the purpose of executing this Exercise of Power and
Irrevocable Assignment.
The assignment did not identify or describe any specific assets
to which it was to apply, and it is unlikely that decedent knew
when she signed the assignment the specific assets that Sidney
Gore and/or the Sidney Gore Trust owned.
Before her death, decedent did not transfer title to any
assets in the Marital Fund to TCO to fund the gifts of $100,000
to each of the Michael Gore and Pamela Powell Trusts.15 After
January 8, 1997, decedent did not execute any other documents
confirming any transfer of assets pursuant to the assignment,
reflecting any gifts of GFLP partnership interests, or
documenting any sale or transfer of assets to GFLP.
15In the estate tax notice of deficiency, respondent
determined that the fair market value of GFLP was $4,997,280.
This figure does not include the two $100,000 amounts assigned to
the children’s trusts that were reported as gifts on decedent’s
gift tax return. However, respondent has not asserted an
increased estate tax deficiency to reflect the estate tax on the
$200,000.
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Last modified: November 10, 2007