Labels:book | reckoner | sky | tree | windowpane OCR: SUMMARY OF ARGUMENT The federal gift tax reaches all gratuitous trars- fers of property, whether direct or indirect, and no matter how "conceptual or cont ingent the property interest may be Smith Shaughnessy, 318 U.S 176. 180 (i943) Ir Jowvett Comm 8sioner the Court held that disclaimer TO remainder interest in trust, which causes the interest to pass the next qualified designated in the trust instru- ment. represents an indirect transfer property interest to which the gift tax "unquestional bly ap- plies 455 U.S. at 310. The Court's holding Jerwett governs this case. The fact that the remainder interest disclaimed in 1979 by Mrs. Irvine was created 11 1917 before the gift tax was enacted in 1932 soep not alter the fact that her disclaimer subject tax. The gift tax applies the ""transfer ...
(.png)
