Planning hints: The effect of the disclaimers
in Letter Ruling 9310020 was substantial.
The IRS ruled that the transfer constituted a qualified disclaimer
within the meaning of Sec.
The taxpayer requested a ruling that written disclaimers
by each of the seven grandchildren would constitute qualified disclaimers
of the property and qualify the estate for an estate tax charitable deduction on the disclaimed property.
THERE ALSO IS a trend in the courts to require investors to pay attention to disclaimers
and warnings in offering statements or prospectuses.
The IRS went on to rule that if the proposed disclaimers
had the effect under Pennsylvania law of removing the tax burden from the residuary estate (i.
In a six-page dissent studded with sarcasm, Scalia and his two allies insisted that the disclaimer
was designed "merely to advance freedom of thought" and did not have a religious purpose.
The IRS included the "disclaimed" amounts in the estate's gross estate, contending that H did not make a qualified disclaimer
of W's property.
Immediately before resigning as administrator, Drye had filed a legal disclaimer
in Probate Court, allowing the estate property to pass to his daughter (who then used the proceeds from the estate to fund the trust).
The committee failed to get a quorum for its December meeting, and as of February still had not issued instructions to publishers about where to post the disclaimers
The Supreme Court affirmed an Eighth Circuit decision holding that a disclaimer
could not avoid a Federal tax lien.
Several months after his mother's death, D filed a written disclaimer
of all interests in T's estate and resigned as administrator.
In December 1989, all 29 legatees signed disclaimers