Labels:book | reckoner | sky OCR: Tape Oral Arg.4/ As a result of the Disclaimer, Mrs. Irvine was treated under Minnesota law T she had died before the Trust's tertnination, and her children became entitied to equal shares of the disclaimed interest ITI with the ters the Trust instriment The State of the Law at the Tine of the Disclaimer Since the enactment of the Gift Tax Act in 1932 Rev. Act of 1932, 501 -532, 47 Stat. 245 59 the established rule has been that disclaimet valid under applicable property iaw would not be transfer 101 federal gift tax purposes. This rule was established Brown Raut zahn F.2d 914 {6th Cir.} (accepting 1931 district court's determination, 58 .zd 329 (N.D. Ohio 1931}. that state law controls) cerf denied. 290 U.S. 647 1933 pue was applied consistently for years in gift tax cases. Commissioner 1 ...
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