Labels:book | reckoner | sky | tree | windowpane OCR: to the gift tax if two conditions are mel : i the disclaimer must be effective under local law and 1 the disclaimer must be made "within reason able time after know] ledge the existence the transfer" (26 25 .2511-1(c) {2}) This Court held in Jewett Commissioner that the "reasonable time' within which the disclai imer must be made runs from the time that the interest being disclaimed was created, rather than from the time the interest vested ard became possessory. 455 U.S 310. 312 In Jewett, disclaimer made 33 years after the inter- est was created was held to be untimely under the regul lation. at 306. 318-319. Mrs Irvine's delay of years was even greater than the delay found untimely Jewett Her 1979 disclaimer there. fore not within the regulatory safe harbor and J mains subject. to tax T ...
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