Labels:book | reckoner | sky OCR: took the pxisition that the "reasonable time' refetenced in the 1958 Regulation began n time the remainder interest created rather thar the time the trust terminated The Eighth ircuit rejected this position, holding under both the 1958 Regulation and Minnesota law the "reasonable time" began to run when th trust terminated The 1963 disclaimer was thus timely F.20 The Government did you seek further review of Keinath and its announced policy the time of Mrs. Irvine's Disclaimer was that would follow Keinath taxpayers residing in the Eighth Circuit See TAM 7829008 {CCH} (Ap1 1978 Mrs. Irvine's Disclaimer was clearly timely for federal gift tax purposes under the 1958 Regu ilation a interpreted in Keinath n Cotfrelt Commissiorer 628 F.2d 1127 (8th Cir 1980}, the en banC Eighth Circuit, the Co ...
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