Labels:book | reckoner | sky | tree | windowpane OCR: filed discla imer of five-sixteenths of her interest in the trust corpus That partial disclaimer wae valid under Minnesota law See Minn. Stat. Ann. 501 .221 {West 1988) result f her dis- claimer each of Mrs. Irvine's five children received -euo -sixteenth of her share OF the distributed trst principal (Pet. App. 32, 52a) Mrs. Irvine filed federal gift tax return for the third quarter of 1979. That return diselosed that she had disclaimed portion of her interest in the Ord- Trust, hut took the position that the disclaimer did not effect transfer of property tr which the gift tax applied. Upon audit, the Comm issioner of Inter- nal Revenue determined that the disclaimer con- stituted an indirect "transfer of property by gift' within the meaning of Sections 2501 {a}(1} and 2511 (a) the Intern ...
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