Labels:book | bulletin board | poster | reckoner | sky OCR: QUESTIONS PRESENTED Whether 1986 Regulation, that by its express terms gaverns only disclaimers OF interests created "taxable "transfers" before 1977 applies a gift dis claimer remainder interest if trust created 1917 fifteen years before enactment ot the federal Gift Tax Act. Whether the taxation of disclaimer remainder interest trust created before enactment the federal Gift Tax Act in 1932 violates Congressional intent that the Act you be retroactively applied change the established discla ler for property interests [b violates the Due Process Clause of the Fifth Amendment in that the time or effective disclaimer by Mrs. Irvine and other taxpayers similarly situated expired before enactment of the Gift Tax Act In the altermative if the 1986 Regulation applies a} whether Mrs. irvine's Di ...
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