Estate of Helen Christiansen, Deceased, Christine Christiansen Hamilton, Personal Representative - Page 32




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          transferor-created interests) or an interest in severable                   
          property that comprises multiple property interests which may be            
          severed (severable property interests).  Generally, each separate           
          transferor-created interest and each severable property interest            
          is treated as a separate property interest.  Id.                            
               Section 25.2518-3(a)(1)(ii), Gift Tax Regs., defines                   
          severable property as “property which can be divided into                   
          separate parts each of which, after severance, maintains a                  
          complete and independent existence.”  For example, if under A’s             
          will B is to receive “personal effects consisting of paintings,             
          home furnishings, jewelry, and silver”, B may make a qualified              
          disclaimer of the paintings and retain the furnishings, jewelry,            
          and silver.  Sec. 25.2518-3(d), Example (1), Gift Tax Regs.                 
          Section 25.2518-3(c), Gift Tax Regs., allows a disclaimer of a              
          specific pecuniary amount to qualify under section 2518.  In                
          effect the regulation treats a disclaimer of a specific pecuniary           
          amount as a disclaimer of a severable property interest.                    
               The distinction between qualified disclaimers of separate              
          transferor-created interests and qualified disclaimers of                   
          severable property is subtle, as shown by the following examples.           
          Assume T devised the income from a farm to A for life, then to B            
          for life, with the remainder interest to A’s estate.  A’s life              
          estate and remainder interest in the farm are separate                      
          transferor-created interests.  A could make a qualified                     







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