home *** CD-ROM | disk | FTP | other *** search
/ The Supreme Court / The Supreme Court.iso / pc / briefs / 1992 / 92_1546 / 1546r035.tif (.png) < prev    next >
Tagged Image File Format  |  1995-08-30  |  75KB  |  1696x2200
Labels: book | reckoner | sky | tree
OCR: Congress enacted Section 2518 of the Code referred to above 1976 providing rule for disclaimers interests created after 1976. The House Ways and Means Committee renort described existing noting that disclaimer 'recognized Federal transfer purposes not treated taxable transfer by the person mak the discla aimer. Rep. No 1380, 94th Cong. 2d Sess reprinted IN 1976 U.S Code Cong News 3356 3419 The Treasury Department likewise, following Congressional intent, has consistently recognized that effective disciaimers are not "transfers" subject to X clear from available early Treasurv Department statements that the Department tollowed the Brown re for years it cases For nple 1945 the Service's Chief Counsel proposed letter ruling that the renunciation Ff interest iT testamentary trust. made before ...