Labels:book | reckoner | sky OCR: valid under applicable property law, and rejected the Government's interpretation of the 1986 Regulation contrary to Congressional intent that the gift stahite not retrpactively applied 56a- 58a Although Eighth Circuit panel initially reversed the district court's opinion, the Eighth Circuit sitting banc on rehearing found that the plain language the 1986 Regulation, limiting its application ta disclaimers interests created T pre- 1977 taxable transfers, was dispositive particularly r light of the Congressional prohibition against retroactive application of the Gift Tax Act. Because the 1986 Regulation did not apply the banc Eighth Circuit held that, based upon Teweti and Hardenbergh, the effectiveness of Mrs. Irvine' Disclainet for federal gift purposes is determined by looking state law ...
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