Labels:book | reckoner | sky | windowpane OCR: complete (and thus taxable), and the Court held that that when grantor relinquished the control he had retained. Neither case has any application donee': refusal accept property, T which no control relinquished because none has ever been acquired See Solamon, 124 F.2d al 89-90 (holding that relinquishment Qf power appointment was not taxable gift and declining to apply Sanford because it was fundamental 1 Sanford that the "person with control over property was either its owner or touop in the first instance ike Estate of Sanford and Guggenheim, the cases cited by the Gov ernment each involved transfer property already owned by taxpayer. Congress has ciearly and consistently intended that taxpayer by disclaimer can effectively tefuse to accept gift. The Government's interpretation of the Ac ...
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