in the Estate of Edythe A. Miller, 446 S.W.3d 445

Richard Miller appeals the trial court's denial of his amended claim in Edythe A. Miller's probate proceeding and the trial court's letter ruling on findings of fact and conclusions of law.
Edythe suffered a stroke in 1993; Richard cared for her after his father died in 1997; Edythe died in 2005.
Richard and his sister were appointed independent coexecutors; Richard filed a claim for reimbursement of loans to Edythe, plus an amended claim with Exhibit B.
Exhibit B is an Agreement for Reimbursement stating loans between Richard and Edythe would be repaid after the death of the parties, bearing no interest and with a ten-year tolling provision.
Appellees argued the Agreement and Richard's loans constituted self-dealing and that the agreement was unenforceable due to lack of proper authority and tolling.
The trial court issued a prejudgment letter addressing the issues, followed by a separate order denying the amended claim; the court did not file formal findings and conclusions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court's letter ruling suffices as findings of fact and conclusions of law.	Richard contends the letter is incomplete and denied him opportunity for further findings.	Appellees argue the letter provides an adequate statement of basis for the ruling and that Rule 296/298 procedures were satisfied.	The letter constitutes the court's findings of fact and conclusions of law for the amended claim.
Whether the amended claim was properly denied based on self-dealing and the power of attorney.	Richard asserts no evidence shows self-dealing and that the power of attorney authorized the transactions.	Appellees argue the Agreement for Reimbursement is self-dealing, unenforceable, and not authorized by the power of attorney.	The trial court's conclusions were correct; the amended claim was properly denied due to self-dealing and lack of authority.

Vickery v. Comm’n for Lawyer Discipline, 5 S.W.3d 241 (Tex. App.–Houston [14th Dist.] 1999) (presumption of validity; use of findings)
Anderson v. City of Seven Points, 806 S.W.2d 791 (Tex. 1991) (fact findings in court cases and appellate review standards)
McGalliard v. Kuhlmann, 722 S.W.2d 694 (Tex. 1986) (review standards for trial court findings of fact)
IKB Indus. (Nigeria) Ltd. v. Pro-Line Corp., 938 S.W.2d 440 (Tex. 1997) (purpose of Rule 296 findings and conclusions)
Cherokee Water Co. v. Gregg County Appraisal Dist., 801 S.W.2d 872 (Tex. 1990) (prejudgment letters are not based on actual findings unless formal findings filed)
Kinabrew, First Nat’l Bank in Dallas v. Kinabrew, 589 S.W.2d 137 (Tex. Civ. App.–Tyler 1979) (strict construction of powers of attorney )
Gouldy v. Metcalf, 12 S.W. 830 (Tex. 1889) (restrict general words by context in power-of-attorney construction)