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OCR: complete with single requirement that the dis- claimer be effective under jocal law The fact that Mrs. Irvine's disclaimer was valid under state law obviously does not, by itsclf estah lish clairner an exemption he from exempt tax and it the did, gift ary tax valid would dis never apply "transfer of property by gift" 26 U.S. 2501 effected by means 0f disclaimer The Court squarely rejected that very contention Jewett. 455 U.S a1 316. The eourt appeals fatled in this case to recog nize the differing sasod.ind behind state and federal timeliness requ rements for disclaimers, 1 State prop- crty law concepts regarding the refusal acccpt nership do not adequately deaI with the federal concern that disclaimers may he used in TE attempt to evade the or estate tax. Statc law which primarily concern ...