Labels:book | reckoner | sky OCR: 8th App. 40 (transcript of oral argument in district court) Despite its representation to the court, the Government never made the change and ultimately terminated the amendment project See IRS Notice 92-12 1992-1 C.B 500 501. Because the plain language of the 1986 Regulation ic of no help to the Government. the Government seeks to justify its interpretation by reiying definition of taxable transfer" found different regulation promulgated interpret different Code provision, Br 26 and citing the Eleventh ircuit case involving disclaimer made Irvine's brother Ordway United States 908 F.2d 890 {11th 1990) cert. denied 2916 (1991) Ordway wa! rongly decided par beca use tht court there incorrectly relied upon Section 2518 of the Code and Treas. R 2{cX{3} 12/ Section 2518 and its implementing re ...