Labels:book | reckoner | sky OCR: from tax20/ that has no in Congressiona! intent and Jewett held that disclaimer indirectly effects transfer nt prop by gift {26 U.S.C. 2501(a) and therefore the federai gift ta sr 15 see atso Jewett did not hold this Justice Stevens wrote he jority in Tewett that disclaimer AY corustitute an indi rect giFl successor iT interest subject to federai gift Hiability 455 U.S. al 306 (emphasis added); see (Jewett presented only question' interpretation of the 1958 Regulation). The Congressional history discussed above shows that disclaimers are not aliowed merely by the grace the Treasury Department, but that Congress has SAOMJE intended that effective disclaimers not De treated "ttansfers" subject tax 21 Estate of Sanford Commissioner 308 U.S {1939} and Burnet Guggenheim 288 280 (1933 cited by t ...
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