In Estate of Christiansen v. Commissioner, 130 T.C. No. 1 (Jan. 24, 2008), Helen Christiansen's will left all of her property, consisting primarily of interests in two limited partnerships through which the family farming and ranching businesses were held, to her daughter, Christine Hamilton. However, Helen's will further provided that if Christine disclaimed any property, 75 percent of it would be distributed to a charitable lead annuity trust (CLAT) created under the will, with the
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