Labels:book | reckoner | sky | tree | windowpane OCR: 3 whether disclaimer constitutes transfer of prop- erty gift" was resolved by this Court ir Jewett where the held that the transfer "by mean 01 disclaimer[] contingent future interest truat' "unquestionably within the scope gift tax (455 U.S at 310 By treating atate law dispositive of the exist- ence of federal gift. tax liability, the court of appeals has perhaps unconsciously resurrected the discred- ited rationale decisions Keineth Com.- missioner 480 F.2d 57 {8th Cir 1973 and Cottrell Commissimr r 628 F.2d 1127 {8th Cir 1980) bano) those cazeS the court of appeals held that because Section 25 .2511 did not specify what "reasonable time, state law con- trolled that determination. Those decisions were relied on hr the taxpayer Jewett for the conten- tion that the dra tsmen of the regulat ...
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