trust income was payable to her husband for life and thereafter to the taxpayer’s parents. Upon the death of the surviving parent, the trust was to be divided equally among her grandchildren then living or, if any grandchild had died, to that grandchild’s child or children. In 1972, some 33 years after the creation of the trust and when the taxpayer’s mother, who was one of the life beneficiaries, was still alive, the taxpayer disclaimed his interest in the trust. The taxpayer argued that the word “transfer” in the Treasury regulation referred to the vesting or distribution of the property and that the “reasonable time” during which he could make a disclaimer did not begin to run until that interest vested upon the death of the last surviving life tenant. See Keinath, 480 F.2d at 63-64 (<HOLDING>). The Supreme Court rejected the taxpayer’s
holding that time within which disclaimer of vested remainder interest subject to divestiture must be filed begins to run when interest becomes indefeasibly fixed both in quality and quantity that is after death of life beneficiary not testator holding that plaintiffs had no vested interest in former interpretation of state law holding that plaintiffs may have a property interest in vested contractual rights holding that the interest must be that created by a claim to the demand in suit or some part thereof  which is the subject of litigation recognizing a broader life interest after a death sentence