Labels:book | reckoner | sky OCR: reconsidered and overruled, because i1 was based upon erroneous information concerning the history of the 1958 Regulation and the Commissioner's interpretation of that Regulation The "Transfer" Referred to in the 1986 Regulation Shouli Construed Mean the 1979 Trust Tgrm ination the 1917 Creation 01 the Trist The Jewett majority in determining that the "transfer" creating Jewett's interest 1939 was the auo from which measure his time disclaim found significant that the only contingency preventing Jewett from taking his fixed fifty percent share trust principal was the requirement that he survive the life beneficiaries. See 455 U.S 318 (petitioner had 50 percent remainder interesi trust tor twenty -four years) (quoting 70 T.C 438) contrast, significant contingencies, addition survival, were ...
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