Labels:book | reckoner | sky | tree | windowpane OCR: 10 clairmed wa.S itself 'taxable transfer' (Pet. App. 5a 6a} The majority reasoned that "absent this lim- itation the gift tax would be imposed on donee's refusal accept gift that never was sub jexct tax the first place, an anomaly that Congress given its clear intent that the gift tax should rot have any retroactive applicat tion, did not ordain (id. at 6a} The maj ajority held that the creat tion of the trust in 1917 15 years before the enactment of the gift tax, did not constitute taxable transfer" within the neaning of the regulation, and that, as result, the regulation' timeliness requirement dit not apply (id at 6a-7a} The majority then concluded that, because Section 25 .2511-1{c} the regulations inapplicable. "gtate gOverTiS the validity of Mrs. Irvine's dis- claimer for federal gi ...
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