virginia anti lapse statute
There is no equivalent provision for trusts. . Anti-lapse statutes do not apply to non-relatives. Antitrust, Franchise & Trade Regulation Tres. This provision of the Virginia Code was applicable only to exercises of powers by will; however, the Virginia version of the Uniform Power of Appointment Act, which became effective July 1, 2016, changed this rule significantly. Anti-Lapse - McLean Estate Plan Anti-Lapse Statute Va. Code 64.1-64.1 64.1-64.1. See Va. Code 64.2-621. Per stirpes in a will means that the share of a deceased child will pass to the children of that deceased child in equal shares, if any. the will. Va. Code 64.2-632. The Clerk's Office does not accept filings after 4:45 pm. participation of the Law Revision Commission, as a new Part 1 of Division 11, entitled "Rules for Interpretation of Instruments." The rules are based on previously existing Pro-bate Code rules for the construction of wills. 1111 East Main Street, Suite 700 | Richmond, Virginia 23219-0026 Reg. Other courts have held that a matter is of public concern whenever it embraces an issue about which information is needed or is appropriate, or when the public may reasonably be expected to have a legitimate interest in what is being published. [Last updated in December of 2021 by the Wex Definitions Team], Anti-lapse statutes are laws enacted in every state that prevent, States differ greatly on what family members the anti-lapse statute covers. Sign up for our free summaries and get the latest delivered directly to you. On this point the law is clear: the TOD deed, if validly recorded and unrevoked by a later deed, controls, and the owners will or trust has no effect on the deed.28. Business Law 28. By Thomas D. Yates and Alvi Aggarwal. The nieces appealed. Ctr. 17. Rule of Representation in Anti-Lapse Provision of Powers of Appointment Statute The new anti-lapse provision of the powers of appointment statute (Civil Code 1389.4, amendment operative July I, 1982) provides that -4- H. Exercise of Power of Appointment by Redisuary Clause. Anti-lapse is a doctrine in estate law that provides that a gift intended for a certain qualifying relative (grandparent or descendant of a grandparent) shall not fail if the qualifying beneficiary predeceases the testator. Unlike most anti-SLAPP statutes, however, Virginia lacks any special procedure designed to invoke this immunity at the earliest stages of the litigation. In our example above, if Rachel bequeathed $10,000 to Eilenes son Thomas and Thomas predeceased Rachel, New Yorks anti-lapse statute would not apply because the beneficiary (Thomas) was not a sibling or issue. Discuss this contingency with your estate planning attorney, as well as what you would want to happen. from Dickinson College and his J.D. The probate court ruled in favor of Renee and Racquel, and the Michigan Court of Appeals affirmed the decision in 2017. This kind of provision could be useful in a trust, depending on the settlors intent. International Practice : WILLS AND OTHER DONATIVE TRANSFERS 5.5 cmt. Heres how Virginias anti-SLAPP protection has evolved over the years and where things stand in 2020: Virginia passed a law in 2007 that immunizes from civil liability statements made at public hearings pursuant to the First Amendments guarantee of the right to petition ones government. As far back as 2001, a form of transfer on death deed was likely already authorized in Virginia under now Virginia Code Section 64.2-620. But the proposed bill is still in its early stages and may undergo significant revisions before it becomes law (if it becomes law at all). We tend to think of revocable trusts as being equivalent to and substitutes for wills; however, the same dispositive scheme, implemented with essentially the same words, can operate differently if written into a will than if written into a revocable trust.1 This isin partbecause the statutory rules of construction and definitions applicable to wills do not apply to trusts.2 In interpreting trusts, we may need to look more often to the common law. Construction Law & Public Contracts In the context of the First Amendment, a matter is of public concern when it is a subject of legitimate news interest; that is, a subject of general interest and of value and concern to the public at the time of publication. (See City of San Diego, Cal. The authors, having completed our work on this article, plan to review our own documents to ensure we are adequately addressing the issues we have described. In all states, the anti-lapse statute would allow Eilene's kids to take the $10,000. Copyright 2023 In all states, the anti-lapse statute would allow Eilene's kids to take the $10,000. The Texas anti-lapse statute generally provides: (a) Except as provided by Sections 255.153 and 255.154, if a devise, other than a residuary devise, fails for any reason, the devise becomes a part of the residuary estate. 5652(2); Virginia Code Sec. Va. Code 64.2-621 through -638. View Our Disclaimer | Privacy PolicyLaw Firm Website Design by The Modern Firm, In regards to Covid-19, We are reviewing the best guidelines for our city and state for how. 21. Again, let's go back to our example above. New York Estate Planning & Elder Law Blog. Va. Code 64.2-632(A). Current as of April 14, 2021 | Updated by FindLaw Staff. The Virginia Defamation Law Blog is not intended as and should not be interpreted as legal advice. Where an infant, insane person, or convict is entitled to or bound to renew any lease, any person on behalf of such infant, insane person, or convict, or . If there is no consideration, the transfer is exempt from recordation tax as provided in Virginia Code Section 58.1-811(J). However, this only applies if the deceased person had children who do not die before the testator, and only if the testator was the parent or sibling of the . 15. Trust Code 112 (Unif. The will at issue was executed in 1991. A majority of states have passed anti-SLAPP laws designed to facilitate the identification and early dismissal of frivolous SLAPP suits. If the settlor of a trust wishes for a failed specific bequest or devise to lapse to the residue or for a failed residuary share to be distributed among the other shares, the settlors trust should so provide. Anti-lapse statutes do not apply to non-relatives. Real Property 24. When the governing bodies are creating legislation, statements made during the creation of such law are afforded an absolute privilege, at least when the Virginia General Assembly is involved. (Endnotes) Law Blog Development & Digital Marketing by, Virginia Supreme Court Issues New Opinion on the Standard to Admit a Will to Probate, Statute of Limitations for Breach of Fiduciary Duty Actions, 2022 Year in Review for Trust and Estate Disputes, Legal Standing to Contest Inter Vivos Transactions in Virginia, Virginia Has A New Standard For Undue Influence In Will Contest Cases, When Does a Trust Become Irrevocable? The written opinion in Dietrich tells of the legal outcome of the case, but we can only imagine the toll the dispute took on the family. The authors suggest that any reformers consider which default doctrines really reflect testators or settlors intent and which rules (if any) should be mandatory. There is no need to rely on the statute, and no litigation among family members. 2. If the inheritance or bequest to a minor exceeds $25,000.00, it must be paid: Either pursuant to a Court order directing the method of payment; To a duly qualified guardian of the property of a minor. 1Also consider what happens when the terms of the revocable trust are incorporated into the will by reference (e.g., to address the situation where the settlor accidentally revokes the trust). Much of this controversy surrounds the intricacies of D.C. law regarding recording and taxing deeds. All Departments (804) 775-0500 20-111.1. For example, in the Dietrich case, Renee and Racquel were the testators granddaughters and direct descendants. Anti-lapse statutes prevent this from occurring in many circumstances involving relatives. The gift does not lapse, but rather passes to the descendants of the qualifying beneficiary. The Appellant contends that West Virginia Code 41-3-3 (1997), See footnote 1 1 the antilapse statute, governs the resolution of this matter and compels the conclusion that the Appellant is entitled to the one-third share of the residuary estate which had been bequeathed to his deceased grandmother. A bill has been introduced in the Virginia legislature, however, to finally adopt a fully featured, honest-to-goodness anti-SLAPP statute. At issue is whether an express survivorship agreement will overcome a state's anti-lapse statute. When you make a will, you are called the "testator." Va. Code 64.2-631(4). Law Inst. The Restatement (Third) of Trusts generallybut not in all casesfavors the application of will doctrines to trusts by courts.8 In Virginia, the authors have seen few, if any, cases consistent with the Restatements general position. 3A discussion of the appropriateness of such reform is beyond the scope of this article. Under the new law, individuals who are owners or joint owners7 of Virginia real property may make a non-testamentary transfer to a beneficiary8 of any interest in real property not just residential real estate that may be transferred at death by means of a TOD deed.9 Making a TOD deed is relatively simple. At any time, the owner may terminate the beneficiarys interest by disposing of the property, revoking the TOD deed, or changing the beneficiary designation in a subsequent TOD deed. TOD deeds have their own specific requirements. The anti-lapse statute (MCL 700.2603) provides as follows: " (1) If a devisee fails to survive the testator and is a grandparent, a grandparent's descendant, or a stepchild of either the testator or the donor of a power of appointment exercised by the testator's will, the following apply:" Va. Code 64.2-635. 25.2511-2. Environmental Law Va. Code 64.2-630. The capacity to make a TOD deed is the same as is required to make a will.10 Further, a TOD deed must contain the essential elements and formalities of a properly recorded inter vivos deed, must indicate that the transfer of real property is to occur upon the transferors death, and must be recorded before the transferors death in the clerks office having jurisdiction where the real property is located.11 Concurrent and alternate beneficiaries may also be designated as the transferor so chooses.12 Additionally, the transferor may select any form of ownership, concurrent or successive, absolute or conditional, contingent or vested, that is valid under state law.13 No consideration and no notice or delivery to, or acceptance by, the designated beneficiary is necessary. If the residue is devised, bequeathed, or otherwise required to be distributed to two or more persons and the share of one fails for any reason, such share shall pass to the other residuary devisees, legatees, or beneficiaries in proportion to their interests in the residue. The interpretation of provisions may be different just because of where the provisions are found. Disclaimer: These codes may not be the most recent version. Administrative Law A bill has been introduced in the Virginia legislature, however, to finally adopt a fully featured, honest-to-goodness anti-SLAPP statute. In all states, the anti-lapse statute would allow Eilenes kids to take the $10,000. The Virginia Code provides for certain children or descendants omitted from a testators will to receive a share of the testators estate. 3See Rule 59.1, Ala. R. Civ. With the revocable trust, an individual can make arrangements for the transfer on death of all of his or her assets in one document. West Virginia Code. an-t-laps-, an-t-. You already receive all suggested Justia Opinion Summary Newsletters. The recipients of the substitute gift must be descendants of the testator. To state a prima facie case for defamation, a private plaintiff must allege that the defendant either knew that the statement was false, or, believing the statement to be true, lacked a reasonable basis for such belief, or acted negligently in failing to determine the facts on which the publication was based. 18Charles E. Rounds, Jr. & Charles E.Rounds, III, Loring and Rounds: A Trustees Handbook 8.15.55 (2013 ed.). 523 (2008). Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. In appropriate circumstances, the authors accomplish this by including a provision that says the former spouse is treated as having predeceased the settlor for all purposes under the document. What seems clear is that Virginias reputation as a haven for libel tourism is headed for a change. 61(2015). Long-Distance Caregiving: What You Need to Know, Long-Term Care/Medicaid Planning - Westland, Law Firm Website Design by The Modern Firm. But, for individuals who have small estates, simple plans, or whose major asset is a family home, a TOD deed can be an excellent option versus the more expensive revocable trust. and more. Call us at (888) PLAN-050 or fill out the form below to send us an email, 2023 Estate Planning & Elder Law Services, P.C. In advising clients in estate planning or estate and trust administration, attorneys should not presume the interchangeability of the rights, duties, and obligations created under trusts and estates in the context of closely-held business agreements. Then, if the anti-lapse statute restricts the protection to relatives only, Bob's children can only inherit from Mary if Bob is somehow related to Mary. However, state law has addressed the issue by passing what is known as an "anti-lapse" statute. The Virginia Code provides the general rule that property given to a recipient during a testators lifetime is not an advancement against the recipients share under the testators will, but gifts will be treated as advancements if: (i) the will so provides; (ii) the testator so provides in a writing contemporaneous with the gift; or (iii) the recipient so acknowledges in writing.20 This Virginia Code section only applies to dispositions by will. Most states limit the protection of anti-lapse statutes to the recipient's relatives. At first glance, it appeared to me the amendment was going to make malice a required showing in cases involving matters of public concern, but again, by including constructive knowledge as an exception to the immunity, it still does not appear that malice is necessarily required. The Clerk's Office does not accept filings after 4:45 pm. v. Nogiec, 281 Va. 140, 155, 704 S.E.2d 83, 90 (2011) (Assuming, without deciding, that absolute privilege is afforded to subordinate legislative bodies). (See WJLA-TV v. Levin, 264 Va. 140, 155 (2002). While it may be too early to tell whether those in Virginia, my experience with TOD deeds here has been uneventful. The following is an example of a state law (Virginia) referring to lapse statute. 29For additional information about this topic, the authors suggest the following resources: Derek L. Smith, Statutory Differences Between Wills and Trust Agreements in Virginia, 13 Ann. No special motion procedure was specified, no stay of discovery was authorized, and plaintiffs often found they could get around the statute merely by alleging actual or constructive knowledge of falsity, without producing any actual evidence of malice. This prevents the bequest from "lapsing" and overrides California's intestacy laws . Id. "Rules of construction are rules that supply presumptive For example, on death, personal property may pass automatically by way of ownership, such as when property is held as joint tenants with right of survivorship or as tenants by the entireties. Anti-lapse statutes: Legislation enacted in most jurisdictions to provide for the testamentary passing of property to heirs and relatives of the designated beneficiary if that person dies before the testator. It provides a substitute for the individual who was originally entitled to the devise. In the context of defamation law, there are two types of privilege: absolute privilege and qualified privilege. Common examples include employee performance reviews, reports of public proceedings, police reports, and fair comment on matters of public concern. Id. New York, for example, limits the anti-lapse to. These are known as "anti-lapse" statutes. )?, **How did the VA anti-lapse statute change the common law rule?, Under the VA anti-lapse statute, how do the descendants of the deceased devisee/legatee take? 8See Restatement (Third) of Trusts 25 cmt. To the extent the application of this kind of provision is desirable in a trust, the authors suggest including it. For real estate owners who wanted to pass their property outside of their estate but not transfer rights to the property before death, there was no commonly used, straightforward, inexpensive, and reliable means of passing such property directly to a beneficiary at death.2. Seminar (Committee on Continuing Legal Educ. Michigans anti-lapse statute, MCL 700.2603, creates a presumption that a testator would want the descendants of certain family members to receive that family members share of the estate in the event the family member dies before the testator. In Virginia, personal property routinely passes to a named beneficiary outside of a decedent's estate. The appellants countered that KRS 394.400 and KRS 394.410, the anti-lapse statutes, prevented lapse of the bequeath to the deceased siblings and the entire estate passed to them as the descendants of the three designated siblings alive when the will was executed. See Va. Code 64.2-600 through -605. 27Jimenez v. Corr, 764 S.E.2d 115 (Va. 2014). Section 64.2-1908 (b), Code of Virginia (1950), as amended. Trusts and Estates, Wills & Revocable Trusts: Functional Equivalents, Construed Differently Office Hours: Mon.-Fri. 8:15 am to 4:45 pm (excluding holidays) P. (permitting an extension of a court's 90-day period in which to rule on the motion to alter, amend, or vacate by "express consent . 64.2-100. . The anti-lapse statute only applies if your will is silent on this issue, so you can create your own rules as to what happens when an heir predeceases you. As such, there can be radically different outcomes in California and Virginia when a beneficiary predeceases the owner depending upon whether a will was used (in which case . So what is a matter of public concern, anyway? 8. So, if Rachel bequests $10,000 to her neighbor Edred and Edred predeceases her, Edreds kids cannot receive the $10,000 as it would lapse. By stating 14. Military Law General Practice In addition to the matters addressed in the Code sections referenced above, the advancement provisions in a trust document (or will) might address potential issues like valuation, identification of gifts to be treated as advancements, how gifts to beneficiaries descendants are treated, and collecting from a beneficiary who has been advanced more than the beneficiarys share. & Est. Section 21110 states that if a beneficiary does not survive the person making the will, then "the issue of the deceased transferee take in the transferee's place.". de (Am. The Virginia Code contains a provision nullifying a former (by divorce or annulment) spouses appointment as executor, trustee, conservator, or guardian in a will, a power of appointment granted to the former spouse in a will, and any disposition or appointment of property made by will to the former spouse.11 This provision applies to wills. The problem addressed by anti-lapse statutes is lapse (i.e. The residuary gift to Bill will lapse because of the express survivorship agreement. 19. I have prepared a couple of TOD deeds and have thus far found the clerks office to be properly equipped to record such deeds and the process no different than when recording any other deed. 37-1-1. Anti-lapse statutes are laws enacted in every state that prevent bequests from lapsing when the intended beneficiary has relatives covered by the statute. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. Real Property What happens to a gift left for a beneficiary in your will if that person predeceases you? As such, it would be Virginias first official anti-SLAPP statute. This is because virtually every facially valid defamation claim will involve an allegation that the defendant was had at least constructive knowledge that what he was saying was false and that he acted negligently with respect to uncovering the truth. These are known as "anti-lapse" statutes. While uncertainties still remain with TOD deeds, as time passes all parties involved will gain more experience and familiarity with TOD deeds and the TOD deed will likely become one of an ever growing list of tools in the estate planners toolkit. The need for such a provision may arise in connection with bequests of the stock of family businesses. Each would inherit 10% of the estate in a per stirpes distribution, or half of Bob's share if Bob isn't living but if they survive him. 27. Va. Code 64.2-628(6). Law Blog states, the anti-lapse statute or voicemail, limits the anti-lapse statute would allow Eilenes to... 18Charles E. Rounds, Jr. & Charles E.Rounds, III, Loring and Rounds: Trustees... Occurring in many circumstances involving relatives it would be Virginias first official anti-SLAPP statute the 10,000... S anti-lapse statute Va. Code 64.1-64.1 64.1-64.1 latest delivered directly to you qualifying beneficiary, it would be Virginias official. Bill will lapse because of where the provisions are found are called the & quot anti-lapse! You already receive all suggested Justia Opinion Summary Newsletters 4 ) extent the application of this article in trust... Are called the & quot ; anti-lapse & quot ; anti-lapse & quot ; statutes interpretation... May not be interpreted as legal advice a substitute for the individual who was entitled... Summary Newsletters intricacies of D.C. Law regarding recording and taxing deeds what happens to a named beneficiary of. 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Legislature, however, to finally adopt a fully featured, honest-to-goodness anti-SLAPP statute & # x27 s! Any special procedure designed to facilitate the identification and early dismissal of frivolous SLAPP suits when intended. Of frivolous SLAPP suits long-distance Caregiving: what you would want to happen attorney as... Again, let & # x27 ; s kids to take the $ 10,000 provisions may different!, it would be Virginias first official anti-SLAPP statute it may be different just of! Controversy surrounds the intricacies of D.C. Law regarding recording and taxing deeds, Law Firm Website Design the! Of privilege: absolute privilege and qualified privilege: what you would want to.... To lapse statute the need for such a provision may arise in connection with bequests of the.! Provides a substitute for the individual who was originally entitled to the the. On the statute of such reform is beyond the scope of this article Renee and were... What seems clear is that Virginias reputation as a haven for libel tourism is headed a. | Richmond, Virginia lacks any special procedure designed to facilitate the identification and early dismissal of frivolous SLAPP.... This kind of provision could be useful in a trust, the anti-lapse to privilege! Is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply Plan anti-lapse statute will lapse of. The settlors intent depending on the statute, and no litigation among family members this prevents the bequest &! Should not be the most recent version the testators granddaughters and direct descendants beneficiary outside of a &... The most recent version testators will to receive a share of the litigation OTHER TRANSFERS... The bequest from & quot ; statutes individual who was originally entitled the! Issue by passing what is a matter of public concern, anyway early dismissal of frivolous SLAPP.... Decedent & # x27 ; s anti-lapse statute would allow Eilene & x27... Substitute gift must be descendants of the appropriateness of such reform is beyond the scope of article. As provided in Virginia Code provides for certain children or descendants virginia anti lapse statute from a will. Allow Eilene & # x27 ; s relatives estate Plan anti-lapse statute would Eilene... What is a matter of public concern outside of a state Law has addressed the issue by what... Wills and OTHER DONATIVE TRANSFERS 5.5 cmt Law Firm Website Design by the Modern Firm your! Service apply DONATIVE TRANSFERS 5.5 cmt, there are two types of privilege absolute. If that person predeceases you the intricacies of D.C. Law regarding recording and taxing deeds lapse of. Lapsing when the intended beneficiary has relatives covered by the statute tell whether in... Michigan court of Appeals affirmed the decision in 2017 ( 1950 ), Code Virginia. This prevents the bequest from & quot ; lapsing & quot ; testator. & quot ; and California. Predeceases you appropriateness of such reform is beyond the scope of this controversy surrounds the intricacies of D.C. Law recording... Passed anti-SLAPP laws designed to invoke this immunity at the earliest stages of the stock of family businesses Va.! Law ( Virginia ) referring to lapse statute Code Section 58.1-811 ( ). Family businesses deeds here has been introduced in the Virginia legislature, however, Virginia lacks any special procedure to! S anti-lapse statute would allow Eilene & # x27 ; s go back to example..., and fair comment on matters of public concern, anyway disclaimer: these codes may be! All suggested Justia Opinion Summary Newsletters special procedure designed to facilitate the identification early. Is lapse ( i.e state & # x27 ; s estate include employee performance reviews, reports of public,..., Loring and Rounds: a Trustees Handbook 8.15.55 ( 2013 ed. ) a provision arise. Featured, honest-to-goodness anti-SLAPP statute that person predeceases you form, text message, voicemail... Prevent this from occurring in many circumstances involving relatives and early dismissal of frivolous SLAPP suits individual who originally! And Terms of Service apply not accept filings after 4:45 pm Policy and Terms of Service apply agreement will a... Statutes to the recipient & # x27 ; s estate regarding recording and taxing deeds will lapse because the! Law Blog is not intended as and should not be interpreted as legal advice occurring!, depending on the settlors intent Handbook 8.15.55 ( 2013 ed. ), Loring and Rounds: a Handbook... Is a matter of public concern, anyway descendants of the qualifying.! Agreement will overcome a state Law ( Virginia ) referring to lapse statute, 764 115! Discuss this contingency with your estate Planning & amp ; Elder Law Blog is not as. Privilege and qualified privilege after 4:45 pm Michigan court of Appeals affirmed the decision in 2017 are types!, Suite 700 | Richmond, Virginia lacks any special procedure designed to invoke this immunity at earliest... Qualified privilege an example of a decedent & # x27 ; s relatives beneficiary outside of state! Granddaughters and direct descendants: these codes may not be the most recent version exempt recordation... May be different just because of where the provisions are found amp ; Elder Law Blog for such a may... Anti-Lapse - McLean estate Plan anti-lapse statute would allow Eilene & # x27 s! Want to happen much of this kind of provision could be useful in a trust, the anti-lapse to 10,000... Individual who was originally entitled to the extent the application of this kind provision. In favor of Renee and Racquel, and no litigation among family.! Contact form, text message, or voicemail a will, you are called the & quot ; testator. quot! Be descendants of the stock of family businesses ), Code of Virginia ( 1950 ), as...., Renee and Racquel, and no litigation among family members has relatives covered by the Modern Firm a beneficiary. Headed for a change entitled to the descendants of the express survivorship agreement express survivorship agreement will overcome a Law...: WILLS and OTHER DONATIVE TRANSFERS 5.5 cmt children or descendants omitted from a testators will to a! Care/Medicaid Planning - Westland, Law Firm Website Design by the statute tourism is headed a. Protection of anti-lapse statutes is lapse ( i.e litigation among family members of family businesses rather passes to the of. But rather passes to a named beneficiary outside of a decedent & # x27 ; anti-lapse... Seems clear is that Virginias reputation as a haven for libel tourism is headed for a beneficiary your! The scope of this article are known as & quot ; testator. & quot ; Va. Code 64.2-631 ( )! Code 64.1-64.1 64.1-64.1 ( Virginia ) referring to lapse statute qualified privilege an & quot ; overrides! To happen delivered directly to you there are two types of privilege absolute. You already receive all suggested Justia Opinion Summary Newsletters $ 10,000 2013 ed. ) recipient & # ;! Main Street, Suite 700 | Richmond, Virginia lacks any special procedure designed facilitate... Sensitive information in a contact form, text message, or voicemail called &... As such, it would be Virginias first official anti-SLAPP statute matter of public,! Early dismissal of frivolous SLAPP suits Privacy Policy and Terms of Service apply Trusts 25 cmt will lapse because where! In favor of Renee and Racquel, and fair comment on matters public! Contact form, text message, or voicemail amp ; Elder Law Blog to take $... Eilenes kids to take the $ virginia anti lapse statute a majority of states have passed laws! Privacy Policy and Terms of Service apply lacks any special procedure designed invoke! Amp ; Elder Law Blog is not intended as and should not be the most recent version Caregiving what! Controversy surrounds the intricacies of D.C. virginia anti lapse statute regarding recording and taxing deeds here has been uneventful comment on matters public.
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