Much of the literature on estate planning refers to gift giving through "Crummey" powers. What are "Crummey" powers and how can one use them to transfer up to $10,000 per year to any one individual tax free while still keeping that money in trust? This article provides an overview to that question.

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What's so crummy about "Crummey" powers?

During the last few years of his administration, President Clinton's budget proposals have included the elimination of "Crummey" powers as a device to pass wealth --- usually from an older to a younger generation --- at little or no transfer tax cost. To understand why the President feels that "Crummey" powers are a tax loophole that must be closed, one first must understand the workings of the federal gift tax.
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NUTS AND BOLTS OF A NEW YORK STATE OFFER IN COMPROMISE: A POSSIBLE SOLUTION FOR CLIENTS WHO DON'T HAVE DEEP POCKETS

Your client telephones your office, frantic, because he has just received a Notice of Determination ("Notice"), showing that he is liable for sales tax, interest and penalties as an officer of his company. There is no question that he is a responsible person for tax purposes; there is also no doubt that he will never be able to pay the amount owed. What can you do to help?

A new client calls, admitting that he filed his tax returns for the past few years but he hasn't paid the tax owed. He's been sick, and his company went out of business. He has a low-paying job now and he's only a few years away from retirement. He's been receiving Notices and he wants to straighten out his affairs with New York State. He hasn't got any spare cash or other assets. What should he do?

SUBMIT AN OFFER IN COMPROMISE

In both of these circumstances, and in many others, a good answer is to file a New York State Offer in Compromise ("OIC"). This is a procedure which may allow a taxpayer to pay less than the full amount owed of tax, interest and penalties. It involves submitting various forms to the State, backed up by documentation and persuasive arguments. If accepted, the liability of that taxpayer is reduced. An OIC can be submitted on behalf of an individual taxpayer or a corporation.
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Because his house was untouched by the storm, his insurance policy doesn't cover the loss. This led me to thinking: Who can John sue?

What about the real estate broker who sold him the property? Maybe we could claim fraud. But the broker didn't represent that the lot was immune from storms. What about the weatherman? There was no warning that the storm was coming until maybe an hour before. But so what? Even if John had been warned, he wouldn’t have been able to do anything to protect his trees.

The more I pondered and researched, the more dead ends I came across. This was one of those cases that they call an act of God. Hence, there is no one to sue. Or is there? If it is an "act of God", God is responsible. Just like anyone else, God should be held accountable for his negligent or mischievous (intentional) deeds.

You may be skeptical. But why? Where is it written that God is immune from suit? I can't find it in the Bible. And it's certainly not written in the Constitution or any statute I can find.

Let's consider the substantive case against God. God created the heavens and the earth, as well as wind, heat and rain, which constitute the framework for unpredictable weather. God also made trees -- in John's case, trees that were not strong enough to withstand God's winds. Whether through design (intent) or oversight (negligence), God should be held liable for his acts. Alternatively, we could sue under a theory of implied warranty. Since God created unpredictable and at times damaging weather, he should have given us trees that can withstand those foreseeable factors. Other possible causes of action, such as fraud or malice, also seem promising.

Suing God poses some unusual procedural questions, though they turn out to be less daunting than they seem. For one, how do you serve God with a summons? Well, consider the purpose of serving a summons. First, to give notice. Since God is omniscient, he knows already. Second, to exercise jurisdiction over the party. In this case, God has jurisdiction over us. That should be good enough.

In what court can we sue God? Most of us will have difficulty with the idea of bringing God into our own civil courts. (Have you seen what the New York courts look like? It's embarrassing, and surely not worthy of God's appearance. But we don't have to. After all, we are taught that God maintains the ultimate court over us. Would God's own court unfairly favor God, putting mortals like John in an unfavorable position? Perhaps. But consider: God is loving and fair. He judges us all the time in matters of greater import, such as who will live and who will die. So we must believe that he is capable of deciding a simple monetary lawsuit, and that he will be fair to John. And there is a precedent for a party to be sued in his own court. For instance, the United States is sued in its own courts, such as the U. S. Court of Federal Claims. If these courts can be fair, surely we can expect no less from God.

Another procedural question is whether God can claim that he is too busy to be bothered with mundane matters, as President Clinton claimed in the Paula Jones case. But the U.S. Supreme Court ruled against Mr. Clinton; and we have to assume that God, who is everywhere at all times, could manage one additional chore. Besides, if God were granted a stay, for how long? God's term, unlike Mr. Clinton's, is forever.

Finally, who will defend God? I propose a form of legal aid. Churches, synagogues and mosques can take turns providing clergymen to represent God on a pro bono basis.

So if you're a lawyer, don't be disheartened the next time a client appears with a case with no apparent defendant in sight. Just declare it an act of God and take it from there.

------------ Mr. Young is a New York lawyer specializing in complex litigation and civil appellate matters.

Historically, a river which is "navigable in fact" has been treated as a public highway even if the banks and the bed of the river are privately owned. Morgan v. King, 35 NY 454 (1866). This rule evolved before there were "planes, trains and automobiles" and when there were few roads in rural areas. Bringing timber, produce or minerals to market from wilderness areas necessitated the use of New York's waterways. Therefore, the courts determined that rivers which are "navigable- in- fact" are subject to a "servitude for transportation". But now there no longer is a major need to use our State's rivers for transportation. What should happen to this doctrine? Before telling the story of Adirondack League Club let's cover some basics.
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Real estate and, since January 1, 1996, stock in a co-operative apartment, owned by married couples have one feature which is unique in the law of property -- the indestructible right of survivorship of each spouse. The failure to consider this concept can lead to unexpected results.

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Mary Ann was excited. She had just closed on her first house. It was February and she could not wait until the weather warmed so that she finally could putter around in a garden all her own.

David was sad. His neighbor for over twenty years had sold his house and moved away. George wasn't the same after his wife Veronica died almost four years ago. "Too many memories in that house, no doubt", thought David. "I'm sure going to miss George's help in the garden."

Spring arrives. Both Mary Ann and David rush outside to start that timeless ritual of getting the garden ready for planting. But what's this? David sees his new neighbor knocking down the fence that encloses his garden. "Excuse me", cries David. "What do you think you're doing?"

"I'm cleaning up my yard", answers Mary Ann.

"But that fence is for my garden. Leave it alone."

"Your garden??", an incredulous Mary Ann responds. "How can that be? This fencing is right in the middle of my backyard -- nowhere near your property."

With that David enters his house and soon reappears holding a 1977 deed. "I bought this plot in the middle of the Hofnauer backyard and have been using it as my garden for the last 19 years. Surely George must have told you."

"No, he didn't. This is the first I'm hearing of this."

"Well your title search should have turned up my deed", says David. "See" -- pointing to the deed -- " it was recorded right after I bought the garden."

"This is impossible," exclaims Mary Ann. "I'm calling my lawyer." So into the house goes Mary Ann, soon to return, saying, "My lawyer says that you have no right to my property. So get off!" David -- in true American fashion -- yells back:

"I'll see you in court."

While no doubt this dialogue never occurred, something similar to this dramatization may have happened just before David L. Bobker instituted litigation to determine his rights to a portion of Mary Ann White's backyard. Their dispute turned out to be a real life application of the rules on tenancy by the entirety. Bobker v. White (Sup. Ct. Putnam County October 27, 1998).
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We finally did it. We didn't want to, but we had no choice.

Exactly nine months after my father-in-law died, my wife and I signed a check for $1,285,000, payable to the Internal Revenue Service.

Now, you may ask what we are complaining about. After all, we were born into enlightened, liberal upper-middle-income families in the 1950s. Our fathers extolled our obligation to pay taxes so that the government can provide for the less fortunate. Indeed, it may have been those principles that dissuaded my father-in-law from engaging in any estate planning. So we had to sign away-in addition to state inheritance taxes, deferred income taxes, excise taxes and countless legal and accounting fees incurred just so we could compute how much tax we must pay-the great bulk of my father-in-law's estate.

Having had the privilege of holding on to this much money for these past months-as executors of the estate we are legally obligated to accumulate and preserve the assets for paying taxes-we dreamed of what we could have done with the funds; buy a beach house, prepay our kids college education, even quit our jobs and retire. Instead, the reality of how fast that money will be spent by the government is hammered home by the giant billboard tallying government debt at the intersection of Sixth Avenue and 43rd Street in New York. I calculate that the federal government will spend in 26.8 seconds what took my father-in-law 75 years to be accumulate-after the taxes he paid during his lifetime. Not a satisfying thought.

We thus propose the following; Rather than paying my father-in-law's hard earned money to the government which acts as no more that a greedy and inefficient middleman between the haves and have-nots. It should simply identify three of the neediest families and let us hand over a half-million dollars or so to each. This way we can know that my father-in-law's money will make a difference. And at least someone would give my father-in-law a posthumous thank-you. Sanford F. Young practices law in New York City. His practice concentrates in complex litigation and civil appellate matters, and his website is www.nylitigator.com.

In the recent post-election litigation between Team Gore and Team Bush, the American public received a good lesson in what a litigator is, and is not.

What was learned is that a litigator is a pit bull. A pure bred animal who is born, bread and trained to do one thing and one thing only, fight to the death for his client.

A litigator's mission is to win at any cost, so long as the client is willing to pay -- whether it be a monetary cost, the loss of political clout, the risk of adverse public opinion or loss of market share. The only limit is the ingenuity of the litigator to articulate some minimal argument of legality and ethics to justify his client's position.

The litigator serves just one master, his client. It is not for a litigator to consider the public good. A litigator cannot weigh the question or what is good for society, the nation, or even mankind. Moreover, a litigator is not supposed to consider his personal welfare. Such considerations are irrelevant, as they may conflict with the interests of the client. Indeed, not only is the interest of his client paramount to any such other considerations, the client's interest is absolute. Competing considerations -- especially those representative of the interest of the adversary --- are dealt with by the opposing position taken by the other side's litigators. Theoretically, or at least hopefully, and maybe sometimes, the societal interest benefits by the results achieved under our adversarial system of justice. That is a long run thing.

Litigators know no limits. They will attack anyone and anything in their path. No prisoners are taken. They are trained to go for the jugular and not to let go. In Florida, that was seen in the way in which Team Gore went after the Florida Secretary of State Katherine Harris, Seminole County Election Supervisor Sandra Goard, and eventually, Judge N. Sanders Sauls for his adverse ruling in the all important Florida contest suit. In turn, Team Bush turned to the United States Supreme Court in its successful and fatal blow to overturn the Florida Supreme Court's decision to direct the manual counts to continue.

It is not for the litigator to decide when to quit or what strategy is off-limits. The client is the commander-in-chief of his legal team, and only that client can call his lawyer off. So long as the client is willing to pay the price, the litigator will find someway for the fight goes on.

In what seems to be an ever increasing number of high stakes law suits, such as the Presidential election cases in Florida and the government's antitrust suit seeking to break up Microsoft, the strategies to be explored, the courts to be visited and the parties and witnesses to be attacked are limited only by the imagination of the lawyers. Moreover, when the party takes a back seat to his legal troops -- placing the litigators in the position to "call the shots" -- the party, in effect, abdicates the only force that can control the lengths to which the litigator is duty-bound to go in the representation of his client. In such a case, the litigation becomes a never ending avalanche that will only cease when the client finally takes control and says "Stop"! Fortunately for the Country, Vice President Gore finally did that when he conceded after 36 days or tortuous and seemingly never-ending litigation.

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WHERE HAVE ALL THE FLOWERS GONE?
The rough terrain of tenancy by the entirety

Real estate and, since January 1, 1996, stock in a co-operative apartment, owned by married couples have one feature which is unique in the law of property -- the indestructible right of survivorship of each spouse. The failure to consider this concept can lead to unexpected results.

Mary Ann was excited. She had just closed on her first house. It was February and she could not wait until the weather warmed so that she finally could putter around in a garden all her own.

David was sad. His neighbor for over twenty years had sold his house and moved away. George wasn't the same after his wife Veronica died almost four years ago. "Too many memories in that house, no doubt", thought David. "I'm sure going to miss George's help in the garden."

Spring arrives. Both Mary Ann and David rush outside to start that timeless ritual of getting the garden ready for planting. But what's this? David sees his new neighbor knocking down the fence that encloses his garden. "Excuse me", cries David. "What do you think you're doing?"

"I'm cleaning up my yard", answers Mary Ann.

"But that fence is for my garden. Leave it alone."

"Your garden??", an incredulous Mary Ann responds. "How can that be? This fencing is right in the middle of my backyard -- nowhere near your property."

With that David enters his house and soon reappears holding a 1977 deed. "I bought this plot in the middle of the Hofnauer backyard and have been using it as my garden for the last 19 years. Surely George must have told you."

"No, he didn't. This is the first I'm hearing of this."

"Well your title search should have turned up my deed", says David. "See" -- pointing to the deed -- " it was recorded right after I bought the garden."

"This is impossible," exclaims Mary Ann. "I'm calling my lawyer." So into the house goes Mary Ann, soon to return, saying, "My lawyer says that you have no right to my property. So get off!" David -- in true American fashion -- yells back:

"I'll see you in court."

While no doubt this dialogue never occurred, something similar to this dramatization may have happened just before David L. Bobker instituted litigation to determine his rights to a portion of Mary Ann White's backyard. Their dispute turned out to be a real life application of the rules on tenancy by the entirety. Bobker v. White (Sup. Ct. Putnam County October 27, 1998).

The facts

On March 5, 1964, George Hofnauer and Veronica Loeffler married. The couple's marriage ended when Veronica died on April 3, 1992. At the time of their marriage, Veronica owned real estate known as Lot 17. On May 9, 1964, she conveyed Lot 17 to "George Hofnauer and Veronica Hofnauer, his wife". The deed was recorded by the Putnam County Clerk on May 13, 1964.

On July 30, 1977, Veronica gave a deed to David Bobker to a portion of Lot 17. For some unknown reason -- probably because no title search was done -- Mrs. Hofnauer was identified on the deed under her previous name -- "Veronica Loeffler". George did not join in the conveyance. Although the Bobker deed also was recorded by the Putnam County Clerk, it did not turn up in the title search commissioned by Mary Ann's attorney because the deed was indexed under the name of "Loeffler" and therefore lay outside George's chain of title.

On February 29, 1996, George sold all of Lot 17 to Mary Ann. The deed from George to Mary Ann was recorded by the Putnam County Clerk on April 2, 1996.

The prevailing principles

Unlike other forms of joint ownership, the tenancy by the entirety enjoys one crucial distinction. The ownership rights of the spouse who outlives the other cannot be destroyed by the unilateral action of the other spouse. First Am. Title Ins. Co. of New York v. Kevlin, 203 A.D. 2d 681, 682, 610 N.Y.S. 2d 361, 363 (3d Dep't 1994) and Lawriw v. City of Rochester, 14 A.D.2d 13, 15, 217 N.Y.S. 2d 113,114 (4th Dep't 1961), aff'd, 11 N.Y.2d 759, 181 N.E.2d 631, 226 N.Y.S. 2d 695 (1962).

"The specific rights arising from this unique form of co-ownership are the logical corollary of the legal fiction that husband and wife were but one person." V.R.W., Inc. v. Klein, 68 N.Y.2d 560,563, 503 N.E.2d 496,498, 510 N.Y.S.2d 848,850 (1986). Where property is held in a tenancy by the entirety "and one spouse dies, the surviving spouse takes the entire estate, not because of any right of survivorship, but because that spouse remains seized of the whole." In re Estate of Violi, 65 N.Y.2d 392,395, 482 N.E.2d 29, 31, 492 N.Y.S.2d 550, 552 (1985). See also, Kahn v. Kahn, 43 N.Y. 2d 203, 207, 371 N.E. 2d 809, 811, 401 N.Y.S. 2d 47, 49 (1977). "As long as the marriage remains legally intact, both parties continue to be seized of the whole, and the death of one merely results in the defeasance of the deceased spouse's coextensive interest in the property." V.R.W., Inc. v. Klein, 68 N.Y.2d at 564, 503 N.E.2d at 498, 510 N.Y.S.2d at 850.

So strong is a tenancy by the entirety that, absent a spouse's death, it may be destroyed only "by certain definitive acts: a conveyance of the property in which both spouses join; a judicial decree of separation, annulment or divorce; or execution of a written instrument which satisfies the requirements of section 3-309 of the General Obligations Law which permits division or partition of real property held in a tenancy by the entirety if clearly expressed in such an instrument". In re Estate of Violi, 65 N.Y.2d at 395, 482 N.E.2d at 31-32, 492 N.Y.S.2d at 552-53.

Bobker bet his begonias but lost.

Let's apply these points to the backyard brawl between Mary Ann and David. By the 1964 deed, George and Veronica Hofnauer became tenants by the entirety in Lot 17. Estates, Powers and Trusts Law §6-2.2(b), Real Property Law §240-b and Armondi v. Dunham, 221 A.D. 679, 680, 225 N.Y.S. 87, 89 (3d Dep't 1927), aff'd, 248 N.Y. 603, 162 N.E. 542 (1928).

In 1977, when Veronica gave her deed to David, the Hofnauers had not employed any of the means by which a tenancy by the entirety can be destroyed, i.e. a joint conveyance, a judicial decree in a matrimonial action or a §3-309 instrument.

This did not mean that the 1977 deed was a worthless piece of paper for "there is nothing in New York law that prevents one of the co-owners (in a tenancy by the entirety) from mortgaging or making an effective conveyance of his or her own interest in the tenancy. To the contrary, each tenant may sell, mortgage or otherwise encumber his or her rights in the property, subject to the continuing rights of the other (citations omitted). Since the status of a tenant by the entirety is reserved exclusively to those co-owners who are married to each other, the interest acquired by a grantee or mortgagee of such a unilateral conveyance is not denominated a tenancy by the entirety, but rather is labeled a tenancy in common. Nonetheless, the grantee's or mortgagee's rights in the property are essentially the same as those possessed by the grantor or mortgagor: a right to shared possession and ownership subject to the original cotenants' reciprocal rights of survivorship. (citations omitted).

"Since the grantee or foreclosing mortgagee, in effect, steps into the shoes of the grantor or mortgagor, his survivorship rights are measured by reference to the lifetimes of the original parties to the tenancy by the entirety. If the grantor or mortgagor predeceases the spouse whose interest in the property has been retained, the grantee or mortgagee is left with no interest in the property at all. Conversely, if the latter predeceases the former, the grantee or mortgagee acquires full rights to the property, unencumbered by the deceased spouse's former interests." V.R.W., Inc. v. Klein, 68 N.Y.2d at 565, 503 N.E. 2d at 499, 510 N.Y.S. 2d at 851.

Thus, David did acquire an interest in part of Lot 17. Unfortunately for him, his interest "died" with Veronica. Since George survived Veronica, he succeeded to the entire estate which meant that when George conveyed title to Mary Ann, she became the sole owner of all of Lot 17, including David's daisies.

Not all gamblers lose

Debra Goldman sued her husband Scott for divorce. To secure payment of her legal fees, Debra's attorney, Phyllis Gelman, had Debra give her a mortgage on the marital residence which Debra and Scott owned as tenants by the entirety. Ms. Gelman recorded the mortgage in 1991. About three years later, Debra and Scott were divorced with Scott being awarded title to the home.

Scott sought to have the mortgage discharged, arguing that since Debra's interest in the tenancy by the entirety was terminated by the judgment of divorce which awarded title to Scott, the mortgage was likewise extinguished since Ms. Gelman's rights in the realty were no greater than Debra's. Goldman v. Goldman, 260 A.D. 2d 537, 540, 688 N.Y.S.2d 601, 604 (2d Dep't 1999) (McGinity, J., dissenting).

Not so, said the Court of Appeals. "(Debra) was legally entitled to mortgage her interest in the tenancy during the pending divorce action. In turn, Gelman acquired a contingent interest in all the rights (Debra) possessed at the time of conveyance (citations omitted). Once the trial court rendered a final judgment of divorce and (Debra's) interest ...transmuted into a tenancy in common, Gelman retained an interest in the tenancy in common (citation omitted). Accordingly, while the distributive award divested (Debra) of her interest in the property, Gelman's bundle of rights, acquired before the final judgment of divorce, was not impaired." Goldman v Goldman, 95 N.Y.2d 120, 122, 733 N.E. 2d 200, -- , 711 N.Y.S. 2d 128, 130 (2000).

Conclusion

As these two cases illustrate, trafficking in conveyances by only one spouse is tricky business. After almost twenty years tilling the soil, David Bobker was certain that he was the owner of that cabbage patch behind Mary Ann White's house. Yet he wound up on the compost pile. On the other hand, knowing that the eventual divorce decree would convert the tenancy by the entirety into a tenancy in common made Phyllis Gelman come out smelling like a rose.

CAUTION

Tenancy by the entirety is a concept which originated in the English common law. Because certain states, such as California, Nevada and Arizona -- to name a few -- were not originally settled by the English, notions of property ownership differ from the "common law" states, such as New York, New Jersey and Connecticut. In California for example, property owned by married couples usually is "community property".

No opinion is given as to how the two cases which are the subject of this article would have been decided in a "community property" state.

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return false;">Michigan</a> <br> <a href="http://www.state.mn.us/courts/library/index.html" onClick="viewHelp('http://www.state.mn.us/courts/library/index.html'); return false;">Minnesota</a> <br> <a href="http://www.mssc.state.ms.us/" onClick="viewHelp('http://www.mssc.state.ms.us/'); return false;">Mississippi</a> <br> <a href="http://www.osca.state.mo.us/" onClick="viewHelp('http://www.osca.state.mo.us/'); return false;">Missouri</a> <br> <a href="http://www.lawlibrary.state.mt.us/" onClick="viewHelp('http://www.lawlibrary.state.mt.us/'); return false;">Montana</a> <br> <a href="http://court.nol.org/" onClick="viewHelp('http://court.nol.org/'); return false;">Nebraska</a> <br> <a href="http://www.clan.lib.nv.us/polpac/nsc/nscl.htm" onClick="viewHelp('http://www.clan.lib.nv.us/polpac/nsc/nscl.htm'); return false;">Nevada</a> <br> <a href="http://www.state.nh.us/courts/home.htm" onClick="viewHelp('http://www.state.nh.us/courts/home.htm'); return false;">New Hampshire</a><br> <a href="http://www.judiciary.state.nj.us/" onClick="viewHelp('http://www.judiciary.state.nj.us/'); return false;">New Jersey</a> <br> <a href="http://fscll.org/" onClick="viewHelp('http://fscll.org/'); return false;">New Mexico<br> </a><a href="http://www.courts.state.ny.us/" onClick="viewHelp('http://www.courts.state.ny.us/'); return false;">New York</a> <br> <a href="http://www.aoc.state.nc.us/" onClick="viewHelp('http://www.aoc.state.nc.us/'); return false;">North Carolina</a> <br> <a href="http://discovernd.com/government/statelaws.html" onClick="viewHelp('http://discovernd.com/government/statelaws.html'); return false;">North Dakota</a> <br> <a href="http://www.sconet.state.oh.us/" onClick="viewHelp('http://www.sconet.state.oh.us/'); return false;">Ohio</a> <br> <a href="http://www.oscn.net/" onClick="viewHelp('http://www.oscn.net/'); return false;">Oklahoma</a> <br> <a href="http://www.ojd.state.or.us/" onClick="viewHelp('http://www.ojd.state.or.us/'); return false;">Oregon</a> <br> <a href="http://www.courts.state.pa.us/" onClick="viewHelp('http://www.courts.state.pa.us/'); return false;">Pennsylvania</a> <br> <a href="http://www.state.ri.us/library/web.htm" onClick="viewHelp('http://www.state.ri.us/library/web.htm'); return false;">Rhode Island</a> <br> <a href="http://www.judicial.state.sc.us/" onClick="viewHelp('http://www.judicial.state.sc.us/'); return false;">South Carolina</a> <br> <a href="http://legis.state.sd.us/index.cfm" onClick="viewHelp('http://legis.state.sd.us/index.cfm'); return false;">South Dakota</a> <br> <a href="http://www.tsc.state.tn.us/" onClick="viewHelp('http://www.tsc.state.tn.us/'); return false;">Tennessee</a> <br> <a href="http://www.sll.courts.state.tx.us/" onClick="viewHelp('http://www.sll.courts.state.tx.us/'); return false;">Texas</a> <br> <a href="http://courtlink.utcourts.gov/" onClick="viewHelp('http://courtlink.utcourts.gov/'); return false;">Utah</a> <br> <a href="http://www.state.vt.us/courts/" onClick="viewHelp('http://www.state.vt.us/courts/'); return false;">Vermont</a> <br> <a href="http://www.courts.state.va.us/" onClick="viewHelp('http://www.courts.state.va.us/'); return false;">Virginia</a> <br> <a href="http://www.courts.wa.gov/library/" onClick="viewHelp('http://www.courts.wa.gov/library/'); return false;">Washington</a> <br> <a href="http://www.state.wv.us/wvsca/" onClick="viewHelp('http://www.state.wv.us/wvsca/'); return false;">West Virginia</a> <br> <a href="http://www.courts.state.wi.us/" onClick="viewHelp('http://www.courts.state.wi.us/'); return false;">Wisonsin</a> <br> <a href="http://www.courts.state.wy.us/" onClick="viewHelp('http://www.courts.state.wy.us/'); return false;">Wyoming</a>

• Quo Jure Corporation
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• Martindale-Hubbell
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• <b>LAW.COM</b>
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• United States Constitution
This site provides a hypertext of the Constitution's provisions that have been amended or otherwise affected by subsequent amendments.

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