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OCR: claim her interest began to run, at the latest, in 1931 when she was aware of her remainder interest and had reached the age ot ma jority (ibid. con cluded that "Mrs. Irvine's partial disclaimer almost 50 years later was not made within reasonable time" (id at 43a-44a Judge Bowman dissented. He stated that Section 25 251] 1-1(c}(2) the regulations "reflects the un- assailable premise that diselaimer FI not subiecl to the federal gift tax unless the transfer creating the intereat disclaimed was "taxable transfer for purposes of the Gift Tax Act" (Pet. App. 44a} cause the contin igent remainder interest that Mrs. Irvine disclaimed in 1979 EPA created in 1917 (id at 48a} ospnr Bowman reasoned that "it never was subject to the federal gift tax and therefore was never taxable transfer for feder ...