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OCR: however, ir suggesting that, hecause the Ordway Trust war created in 1917 before the gift. tax was enacted, taxing Mrs. Irvine' 1979 discla imer of her interest ir the trust 'apply the tax retro actively (ibid. The court similarly erred FUg- gesting fid ja n.2 7a) that this Court's decision ir Jewett -which concerned the diselaimer 0f terest in trust that was created in 1939 after the tax was enacted. -15 distinguishable on that basis. The gift tax applies to the transfer of property by gift' [26 U.S.C. 2501 (a)(1)) Many property rights currently existence created before 1932 Iong the "transfer" that is the subject of the tax occurred after 1932, it is irrelevant when the property right being transferred was created See Revenue Act of 1932 ch. 209 501 {b} 47 Stat. 245 The court appeals sim ...