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OCR: Act in 1932 Ir short, the Government admits that Mrs Irvine had no time make effective disclaimer Action by the Lower Courts Both the district and the en banc f harsh Appeals for the Eighth Circuit rejected the Gove Regulation emment's and retroactive application the 1986 concluded that Vr Irvine's Disclaimer was nou transfer for federal gift tax purposes. The district court held that disclaimers pre Art interests like Mrs Irvine's -TE effective for federal gift tax purposes long as they are Court: When in your view must she have auap the disclaiming to have been teasonable? Mr. Paup Well, the regulations don't establish bright line. Court But what' the Government' position Mr Paup position that T bar to within reasonabic time Court t what, Mr. Paup to what? Mr. Paup Within reasonable time ...