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FEDERAL INCOME, ESTATE & GIFT TAX PROJECT i (SUMMARY OF PROPOSED REVISIONS OF TENTATIVE DRAFT 10)

handle is hein.ali/aliftp0288 and id is 1 raw text is: Summary of Proposed Aevisions
Tentative Draft 10
Note: The revisions proposed herein were made in an attempt to meet
the points raised at the 32nd Annual Meeting of the American Law
Institute, in May, 1955, with respect to Tentative Draft 10. Accordingly,
it is necessary that this material be read in conjunction with Tentative
Draft 10. Where no reference has been made to a section in either the
draft or the comments thereto, the section remains the same as in
Tentative Draft 10.
I. SECTION X1007(e). EXCLUSION Of DIVORCE, SEPARATION,
AND ANNULMENT TRANSFERS AND TRANSFERS
BETWEEN FORMER SPOUSES.
The exclusion permitted by this section has been greatly
reduced by the addition of the following requirern nts:
(1) that the transfer take place within two years previous to
or following the divorce and
(2) that the transfer be pursuant to a written agreement, or
in modification of a prior property settlement.
11. SECTION X1007(h). EXCLUSION O   RENUNCIATION OF AN
INTERE'ST IN PROPERTY.
The exclusion permitted by this section has been extended to
cover interests in property obtained as the result of inter vivos trans-
fers. Provisions have also been added to clarify the meaning of the
reasonable time requirement in certain troublesome situations--e.g.
when the donee is a minor or incompetent at the time of transfer, or
when the interest in property is the subject of litigation for a time after
the initial attempt at transfer is made,

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