Labels:book | reckoner | sky | tree | windowpane OCR: court therefore concluded that the gift tax could not apply to the disclaimer in this case (Pet. App. 57a) In reaching its conclusion, the distriet court noted that another district court had reached the same conclusion or virtually identical facts' in case volving partial disclaimer one Mrs. Irvine's brothers his remainder interest 11 the Ordway Trust (Pet. App. 58a, citing Ord way Urrited States, 89-1 U.S.T.O {CCH} 113. 802 Fla Mar. 13 1989) The court stated that found the reasoning of the ""indistinguishable" Ordwoy decision to be "compelling" (Pet. App. 58a) divided panel of the court of appeals re- versed (Pet. App. 29a-49a). Judge MeMillian, writ ing for the court. noted that the Eleventh Cireuit, Ordway United States, 908 F .2d 890 (1990) cert. denied. 111 2916 (1991) had reversed t ...
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