Labels:book | reckoner | sky OCR: the creation of the interest. 1n that private letter ruling the Commissioner allowed taxpayer with knowiedge at least since 1936 an income interest trust IT 1933 to disclaim Free of gift a 1966 when she became entitled an additional income share See JA (PLR 6612201 590A (Dec 20 1966); 52e alsa The relevant "transfer' the Service applied 1958 Regulation in that ruling was contingency eveni entitling the taxpayer gteater incone share, ro the creation of her interest 1933 Since Jewett. three circuit courts of appeals, in cases involving the timeliness of disclaimer survivorship interest in jointly heid have confined Jewett's definition ot transfer to it facts ln these cases, the courts appeals have held that because state property aw permitted jpint tenant sever the joint tenancy strip the ot ...
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