Labels:book | reckoner | sky | tree | windowpane OCR: able time after knowledge of the existence of the transfer" (26 C.F.R. 25. .2511-1(c) (2}) This Court held Jowett that the "reasonable time within which the disclaimer must be made runs from the timc that the interost being disclaimed was created, rather than from the time that the interest vested and became possessory. 455 U.S. at 310 Jewett, the trust was established in 1939 but the paver did not disclaim his contingent remainder in- terest until 1972. The Court held that the disclaimer filed 33 years after the interest was created was untimely at 306 318-319 The safe -harbor regulation creates an exception from the gift tax that does not exist m the face nt the statute Jewett, the Court rejected the taxpayer's argurment that the regulation affording "reasonable time* for disclaimer esca ...
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