Labels:book | reckoner | sky OCR: 33 the tax statute in this case. 25/ If the Goyernment's const ruction of the Act and the 1986 Regulation were accepted, this Court PInDM have 51 reach this significant due process issue And if the Court does reach this issue the Government should be struck down violation of Mrs Irvine right to due process because she, without notice would e taxed arbitrarily for ne legitimate with regard to conduct undertaker vears before enactrent OF the Gift Tax Act. In the Alternative the 1986 Regulation Applies This Court Should Hold that Mrs Irvine's Disclaimer was Timely and Effective Federal GiftTax Purposes. As separate, alternative ground for affinmance, the 1986 Regulation does apply this Court should hold that Mrs. Irvine's Disclaimer, made within reasonable time after termination of the Trust ...
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