Labels:book | reckoner | sky OCR: The Goverrnents Assessment of Tax Nearly three years after Mrs. Irvine's Disclaimer. this Court decided lewett. which involved 1972 disclaimer of fixed fifty percent remainder interesl trust 1939 The Jewett rajority held that the ambiguous 1958 Regulation required the taxpayer disclaim his interest within reasonable time the 1939 transfer, not the event causing the trtst terminate (which had not yet ccurred) 455 318 Jewet thus rejected Keinath's interpretation the 1958 Regulation the context OF the facts presented The IRS assessed the tax against Mrs Irvine in 1982 immediately fewett decision, apparently believing that lewet interpretation 1958 Regulation controlled Irvine' case Mrs Irvine immediately paid the asserted liability then filed an administrative claim FO Iefund the erroneously ...
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