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OCR: 16 The Court's holding in Jewett applies directly the 1979 disclaimer by Mrs. Irvine 1 her remainder interest the Ord MEM Trust. The determination ir Jervett that diselaimer transfer subject the gift tax disposes of that same issue this casc. Bee also note The Fact That The Ordway Trust Was Created Before The Federal Gift Tax Was Enacted Is Not Relevant The court of appeals correctly noted that, in enact- <s ing [t]he the tax federal shall gift not tax apply Congress transi fer specified made that before the date of the enaetment this Act June 1932.] Revenue A cf 1932, cn 209 501 Stat. 169 245* {Pet. App Ta} The court erred, the gift tax statute. The transfers of "property" to which the gift tax applies include transfers "conti ingent well as possessory interes See 455 U.S 309 810. citing ...