Labels:book | reckoner | sky OCR: Mrs. Irvine's Disciaimer would similarly be an unfair retroactive application of the Act The Government in the district court papasudd that itr application ot the 1986 Regul lation Mrs. Irvine was retroactive. I 17-18 The Govermment the Eighth Circuit conceded that Mrs Irvine had n0 opportunity to make an effective disclaj mer But here, the Government says that because her Disclaimer was made IT 1979. there no retroactive application of pur the that her interest was created before the irrelevant. it Aside from mischa racterization of the Jewett holding that Gov ernment's sole application the Gift Tax Act Was unfairly retroactive 1936 Sect tion 501{b} even though the asset trans fers took place and 1944 The en banC court of appeals did you suggest that taxing Mrs. Irvine's 1979 Disclaimer w ...
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