Labels:book | reckoner | sky | tree OCR: II. MRS. IRVINE'S 1979 DISCLAJMER NOT PRO. TECTED 1Y THE REGULATORY SAFE HARBOR FOR DISCLAIMERS MADE NIHLIA "REASON- ABLE TIME" F THE ESTABLISHMENT THE TRUST The Treasury Regulations on Gift Tax imple- ment the broad scope the federal tax by providing that "any transaction which an interest ir prop- erty gratuitously passed or conferred upon another regardless of the means or device employed, consti- tutes gift subiect tax (26 C.F.F 2 .2511- 1(e)(1) Sinec the prom lgation these regula- tions ir 1958. howev ver the Commissioner it Internal Revenue has recognized narrow exeeption, or safe harbor, to this general rule of taxability. See 24 C.F.R. 25 2511-1 {c} {1958} Pet. App. 60a -61a. Both 0r iginally and 1m their current form, the regul lations provide that refusal accept ownership of prop ...
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