Labels:book | bulletin board | poster | reckoner | sky OCR: under Minnesota law does not satisfy the federal gift. tax concern that Mrs. Irvine's 48 -year delay "made likely that the renunciation decision wae part of the taxpayer's personal estate planning" (Jewett Commissioner, 455 U.S 316 n.17 Because Mrs. Irvine waited 48 years disclaim her interest in the Ordway Trust. her disclaimer was not made within the "reasonable time" required obtain the protection the regulatory safe harhor The 1979 disclaimer her interest ir the Trust represents transfer of property by gift (Jewett Commissioner 455 U.S. 310 and therefore properly subject t the federal gift tax. CONCLUSION The judgment of the court of appeals should be reversed, Respectfully submitted. DREW DAYS 111 Soticitor Generat MICHAEL L. PAUP Acting Asoistant Attorney Gereral LAWRENCE WALLACE Dep ...
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