Labels:book | reckoner | sky | tree OCR: 76 pIcted gift for Federal gift tax purposes regardless tO whether gift tax is imposed 011 the completed gift. 26 C.F.R. 25.25 18-2 {3] For t.he purpose of measuring the time ir which tr tax-: -tree dis- claimer, taxable transfor" oceurs under the regu lations "whenever there happens 'any transaction which an interest in property gratuitously passed OF conferred upon another. ever that transaction was not subject to the gift tax Ora Umited States, 908 F.2d at 895. quoting 26 C.F.R 95 2511-1 {c)(1)). Under this express regulatory definition. the irre- vocable transfer in trust made Irs Irvine's grandfather m 1917 constitutes "taxable transfer' for purposes of the disclaimer regulation even though that transfer was not subject the gift tax" (26 C.F.R. 25.2511-1(c)(1)) Hence, whether the in- ...
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