Labels:book | reckoner | sky | tree OCR: fect when Mrs Irvine made her disclaimer applies to this case' Pet App. 12a} Judge Loken noted that "[the regu lation initially promu Igated 1958 did not contair the current regulation's refer. ence 'taxable transfers ibid.) his vlew "this prior version of the regulation does not apply ir this case because it only applied to property trans- ferred from decec dent, whereas the interest Mrs. disclaimed was created by an inter vivos trust" {id. at 13a Judge McMillian filed dissenting opinion ir which Senior Judges Lay and Bright and Ju ge Gibson joined. their view "the majority opinion's in terpretation "taxable transfer as transfer made after the enaetment of the federal gift tax too narrow" (Pet. App. 17a} They have followed the Eleventh Circuit's decision ir Ordway and held that the reason ...
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