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OCR: 1 in 1979. however, is a separate and distinct trans- action. Mrs Irvine's remainder interest in the Ordway Trust was valuable property interest, even though it SPM subject to contingencies and did not become possessory until immediately before she partially dis- claimed it in 1979. Sce Jewett Commissioner 455 U.S. at 318 319 Commi issioner Procter, 142 824. 826. -827 (4th Cir.). cert. denied, 878 U.S. 756 (1944) After the death of her father in 1966 Mrs. Irvine became entitled to receive share come of the trust each year. Moreover, for 48 years, Mrs Irvine possessed the power decide the ulti- mate disposi ition of her remainder share the corpus of the trust, and she relinquished that power only after her interest became possessory in 1979. precisely upon the relinquishment of her power co ...