Labels:book | reckoner | sky | tree OCR: tion even though a tax had not been imposed on that YJ18 Judge MeMillian concluded that the establish- ment the Ordway Trust represented "taxable transfer" under the regulation and that the regu tion 15 therefore potentially available as mechanism to permit timely disclaimer by Mrs. Irvine es- cape tax Pet. App. 37a} 1n Jewett, however this Court held that the "rea- sonable time" for disclaimer to be made runs from the time "when the disclaimed interest was created and not later when that interest vested' Pet App. 39a citing 455 U.S. at 312 318-319). Since Mrs. Irvine disclaimed her remainder interest 1979. which "some years after she first became aware of her interest, Judge MeMillian stated that the diselaimer "was clearly t00 lato" (Pet. App 39a} Senior Judge Bright filed concurring opi ...
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