Estate of Leona Engelman, Deceased, Peggy D. Mattson, Executor - Page 9

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          several more narrowly defined classes of assets.  Among these               
          specific sections are section 2036, which includes transfers                
          where the decedent retained the possession of, the enjoyment of,            
          or the right to designate persons who shall possess or enjoy                
          transferred property or income therefrom; section 2038, which               
          includes revocable transfers; and section 2041, which includes              
          property over which the decedent held a general power of                    
          appointment.                                                                
               However, inclusion of certain assets in the gross estate may           
          be avoided through operation of the disclaimer provisions of the            
          Internal Revenue Code.  For purposes of the estate tax, section             
          2046 incorporates by reference section 2518, which reads in part:           
               SECTION 2518.  DISCLAIMERS.                                            
                    (a) General Rule.--For purposes of this subtitle,                 
               if a person makes a qualified disclaimer with respect                  
               to any interest in property, this subtitle shall apply                 
               with respect to such interest as if the interest had                   
               never been transferred to such person.                                 
                    (b) Qualified Disclaimer Defined.--For purposes of                
               subsection (a), the term “qualified disclaimer” means                  
               an irrevocable and unqualified refusal by a person to                  
               accept an interest in property but only if--                           
                         (1) such refusal is in writing,                              
                         (2) such writing is received by the                          
                    transferor of the interest, his legal                             
                    representative, or the holder of the legal title                  
                    to the property to which the interest relates not                 
                    later than the date which is 9 months after the                   
                    later of--                                                        








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