Labels:book | reckoner | sky | tree | windowpane OCR: the dissenting judges correctly in this case "the majority opinion seeks inject the issue retroactivity into this case where nonc actually exists {Pet. App 222 -23a Jacobs, the post-enactment transfer br disclaimer ot Mrs Irvine's interest the pre. enactment trust repre- sented change the nature of ownership of prop erty [that] was designated by Congress as an appro- priate occasion for the imposition of tax {306 U.S. at 371] ment in 1931 under which the prospective hushand agreed to million to his future wife upon domand at any time after their marriage return, she surrendered any other marital property rights to which she may have heen entitled I1 fulfillment of this pledge, the husband transferred $500,000 in securities to his wife in 1936 and the same amount in 1944. Although such tran ...
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