Estate of Chamberlain v. Commissioner

*714MEMORANDUM **

The estate of Theodore Chamberlain and Dale Chamberlain (collectively “Taxpayer”) appeal the decision of the United States Tax Court. Taxpayer argues that the Tax Court erred in holding that Mr. Chamberlain failed to make a qualified disclaimer of assets in his wife’s estate for purposes of I.R.C. § 2518. The failure to make a disclaimer resulted in an inheritance tax. We affirm.

Taxpayer argues that a handwritten, unsigned schedule of assets and the probate inventory are qualified disclaimers. Neither document expresses an intent to disclaim. Both are simple lists of assets of a…