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disclaimer of all or an undivided portion of either the income
interest or the remainder. See sec. 25.2518-3(a)(1)(i), Gift Tax
Regs. Although the life estate and the remainder are separate
transferor-created interests, neither is severable property.
Thus, A could not make a qualified disclaimer of the income from
the property for a term of years. Sec. 25.2518-3(a)(ii), Gift
Tax Regs.
By contrast, assume T devised a fee simple in the farm to A.
Neither a life estate nor a remainder interest in the farm is a
separate transferor-created interest, nor are they severable
property interests. See sec. 25.2518-3(b), Gift Tax Regs. Thus,
A could make a qualified disclaimer of all or an undivided
portion of the farm but could not retain a life estate and make a
qualified disclaimer of the remainder. See id.; see also
Walshire v. United States, supra at 349.
If the farm consists of 500 acres of land and 500 head of
cattle, the farm is severable property with respect to the land
and the cattle; i.e., if the cattle are severed from the land,
the existence of the cattle will be complete and independent of
the land and the existence of the land will be complete and
independent of the cattle. Thus, A could retain the land and
make a qualified disclaimer of the cattle or retain the cattle
and make a qualified disclaimer of the land. Further, the land
and the cattle each may be divided into two or more parts, each
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