Labels:book | reckoner | sky | tree OCR: the Lrust in 1917, fifteen years before the tax was enacted, did not constitute "taxable transfer" within the meaning of the regulation and that. result, the regulation' "reasonable time" provision docs not apply in this case (Pet. App. 6a-7a the Eleventh Circuit correctly recognized in Ordwa! United States, 806 F.2d at 895. however. the term taxable transfer" in the amended regula- tion merely refers transfer that completed gift whether or not gift tax was actually iniposed. The preex risting disclainer regul lation (26 C.F.R 25.2511- 1(c} 1958 was amender in 1986. See note supra The amendment wa: designed conform the regulations under Section 2511 the new regulations being promul Igated at the same time under Section 2518 of the Code. See 45 Fed Reg 48. .922 {July 22, 1980 Section 2518 o ...
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