Labels:book | bulletin board | poster | reckoner | sky | vegetarianism OCR: Page H Application of the 1986 Regulation to Pre Act Interests Would Violate ongr ressional Intent and the Due Process Clause Congress Has Consistently Provided that Effective Disclaimers Are Not Transfers Subject Federai Gift Tax Congress has Consistently and Repeatedly Directed that New Disciaimer Rules Are Nat Retroactively Applied Existing Interests Taxation of Mrs Irvine's Disclainer Under the Government' Construction of the Gift Ta and the 1986 Regulation Would Violate Due Process C. In the Alternative, if the 1986 Regulation Applies This Court Should Hold that Mrs Irvine's Disclaimer was Timely and Effective for Federal Gift Tax Purposes The Referred to in the 1986 Regulation Should Construed to Mean the 1979 Trust Ternination Rather than the 1917 Creation of the Trust Inter ests Ci ...
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