Your manager advises you that clients Mike and Winona Marsh, residents of Bath, Maine, acquired beachfront property in Maine in 2002 and titled the property in their names as joint tenants with right of survivorship. Under Maine law, either joint tenant can sever the joint tenancy unilaterally. Mike died in July 2020, survived by Winona and their two adult children. His will provided that all his property passes to Winona if she survives him. Otherwise it passes to the children equally. In September 2020, Winona executed a written disclaimer of the one-half interest in the beachfront property that otherwise would pass to her by survivorship. As a result, this interest passed to the two children equally. Winona and the children represent that Winona has not accepted the interest in the property or any of its benefits. Your manager requests that you research the issue of whether Winona made a gift to the children when she disclaimed and that you address your conclusions in a memo. She recommends that you search only in private letter rulings.