Labels:book | reckoner | sky OCR: the 1986 Regulation, rejected the Govermment's untenable construction. See American Tobacco Co Patterson. 456 U.S (1982) tinterpretations should "avoid untenable distinctions anc unreasonable Iesults whenever possible" Its holding was correct and should affirmed fundamental that for a transfer DE "taxable" there must be an applicabie tax existence when the transfer is made See PA 7a Congress explicitly directed i1 1932 that the federal gift tax "shall not apply transfer made on or before the date of enactment Act (June 1932]. 501(b) and continuec that prohibition revisions the Act to the present See 2502(b) (current vers ion) 10 ight that 'consistently expressed intent the banc court jected the Government's view that "the term taxable trars [the 1986 Regulation] ran refer transfer made bef ...
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