Ohio University, A.B., with honors, 1959
Law School Attended:
University of Cincinnati, J.D., with honors, 1962
Year of First Admission:
2013, Recognized by The Florida Bar as a 50 year Senior Counselor; 1963, U.S. District Court, Southern District of Ohio; 1981, U.S. District Court, Middle District of Florida; 1967, U.S. District Court, Northern District of Ohio and U.S. Supreme Court; 1989, U.S. Tax Court; 1962, Ohio; 1980, Florida
Collier County (Member, Sections on: Real Estate; Trust and Estate) and American (Member, Sections on: Business Law; Antitrust Law) Bar Associations; The Florida Bar (Member, Sections on: Business Law; Real Property, Probate and Trust Law).
U.S. Naval Reserve; Active Duty 1952-1954
Powell, Marion Estate, TC Memo 1992-367, Code Sec. 2036, RIA TC Memo §92367, 63 CCH TCM 3192. Decedent transferred annual fractional interests in the residence to her children to take advantage of the annual gift tax exclusion. After the first such transfer, Decedent moved to a retirement community and did not return to the residence. At her death, Decedent and her children owned the residence as tenants in common. The Court held that there was no agreement, expressed or implied, that the residence would remain the home of the Decedent; that her right as a tenant in common did not cause her to be in possession or enjoyment of the cotenancies transferred; and thus, only the value of the Decedent's cotenancy was includable in her gross estate under IRC Sec. 2036(a).
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