Labels:book | daily | jotter | reckoner | sky | tree | windowpane OCR: terest disclained by Mrs. Irvine was created before 10 after enactmont of the federal gift tax her failure to discl aim her interest "within reasonablo time" precludes her reliance in he safe-harbor provisions of the regulation. The "reasonabIc time" requirement of the regula- tion addresses the question of "how long" the dis- claimant has been aware of the property interest, not whether the property was initially transferred m trust on taxed or tax-free basis. Whether or not the. interest disclaimed created before the federal gift tax was enacted is you relevant under the regula- tory safc harbor provision. Under the express terms 10 Sections 25. 2511-1(c) (2 and 25. .2518 2c) {3} of. the regulations, iong as the transfer efrected completed gift of property, then the transfer 'taxable tra ...
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