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OCR: Minnesota law and thus is mou transfer subject to under the federal gift tax. Application of the 1986 Regulation to Pre-Act no Interests Would Violate Congressional Iutent the Due Process Clause J1 the Court finds that the "taxable transfers language does you limit application to post Act interests, 1986 Respandents submit tha application he interests Congressional intent under Process Regulation nevertheless its Clause D could the vjolates 9861 have Regulation 1986 Regulation. and conceded effective the Mrs. Due that for The Government has interpretation of the Irvine never made disclaimer always federal gift tax pasodand Congress, however has intended that an effective refusal to accept property, means ot disclaimer not be treated "transfer" of property gift its Congress also has must co ...