1. David's will provides:

"I leave Blackacre to my son, Abel. I leave $1,000,000 to my

daughter, Brenda.

I leave my IBM stock to my daughter, Carol.

I leave Whiteacre to my son, Edward.

I leave the residue of my estate to my spouse, Sandra.

If any of my beneficiaries predeceases me, or is treated as

predeceasing me under state law, that beneficiary's share of my

property will pass to that beneficiary's issue."

Abel and Brenda each have two children; Carol has one child;

and Edward has four children. David dies survived by his spouse,

Sandra, his four children, and his nine grandchildren.

a. Abel wants to pass Blackacre to his two children immediately. If he

disclaims his interest, will that happen? What are the gift tax

consequences of his disclaimer?

b. What are the gift tax consequences if Brenda disclaims an interest

in $600,000?

c. What are the gift tax consequences if Carol disclaims her interest in

one-half of the IBM stock?

d. What are the gift tax consequences if Edward wants to disclaim part

of his interest in Whiteacre? Can he make a qualified disclaimer of

a specific portion of Whiteacre, for example, of the "south 40

acres"?