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OCR: the 1939 Code, also not before the Court, which nowhere mentioned disclaj imers included any examples suggesting that refusal accept gift was "transfer of property See supra The Court also did you ha before internal Treasury Department memorandum prepared shortly before the publication the federal gift tax regulations in proposed form in 1957 explaining that only six reguiations represented major changes from existing regulations, ajl the "direct result of the enactnent of the 1954 Code. proposed regulation regarding disclaimers was not among therm.32/ These docunents strongly. 1 not conclusively show that the 1958 Regulation merely was intended continue the Treasury Department's historic position regarding disclaimers, following the tule This is reinforced by the fact that the Depar rtmen ...