Labels:book | reckoner | sky | tree OCR: 14 if The the court safe-harbor of appeals provision also erred in inapplicable concluding to that, the taxpayer's disclaimer, then the disclaimer escapes tax simply because was valid under state An invalid disclaimer, course would not effect "transfer" t property, gift otherwise. valid disclaimer that fails to qualify under the safe- -harbor provision, however TE taxable under the general pro- visions of the regulation and the statute. Jewvett this Court unequivocally rej jected the contention that state taw governs the taxability of disclaimers under the federal gift tax. 455 316 disclaimer the that is valid reasonable under time state law requirement but of that the fails federal satisfy reg- ulation is subject to the federal tax. Ibid. ARGUMENT I. THE JRVIN FS FEDERAL DISCLAIMER GIFT T ...
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