Labels:book | reckoner | sky | tree | windowpane OCR: McDonald Commissioner, 853 F.2d 1494 1499 (8th Cir. 1988) cert. denied, 490 U.S. 1005 (1989)) He concluded that here Jewett, the discla imer constitutes ian indirect gift successor inter- est subjcct to federal tax liability (Pet. App 35a, quoting 155 at 306) Judge McMillian further concluded that Mrs. Irvine failed to come within the regulatory safe habor for disclaimers that oceur "within reasonable time after the taxpayer acquires knowledge of the intereat being discla imed (Pet. A.pp. P68 40a) This sa] fc-harbor proy ision, Section 25 2511-1 the gift tax regul lations states 1n pertinent part as lOWe C.F.R .2511-1c){2 emnhasis sup- plied) In the case of taxable transfers creating an in- terest in the person disclaiming made hefore January 1977 refusal accept owner- ship does constitute ...
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