Labels:book | jotter | reckoner | sky | tree | windowpane OCR: correct, it would serve only to narrow the exception to taxability disclaimers set forth Section 25 .2511-1(c) ot the regulat tions would not allow the disclaimer to escape tax. The court of appeals further erred in conclud- ing that. the "reasonable time" requirement Section 25 2511-1(c) (2) the regulations applicable this case, then "state law governs the validity Mrs. Irvine's disclaimer for federal gift tax purposes {Pet App. 10a} Based on this errone- ous conclusion, the court held that, hecause Mrs. Irvinc's disclaimer valid under Minnesota law (id at lla): her "disclaimer therefore is not trans- fer upon which gift tax owed" (ibid.) he analysis applied by the court appeals in this case S specifically repudiated by this Court in Jewett TF Commissioner The validity of n the disclaimer ...
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