Quinto DePaoli Sr. died and was survived by his wife, Soila, and his son, Quinto Jr. (plaintiff). The DePaolis were New Mexico residents. In his will, Quinto Sr. left his entire estate to Quinto Jr., who had two nonmarital children. Quinto Jr.’s federal tax return showed that he had disclaimed his inheritance above $600,000, which was the maximum amount not subject to the federal gift tax and that the remainder of the estate passed by intestate succession to Quinto Sr.’s surviving spouse, Soila, and was therefore entitled to a marital deduction. The Internal Revenue Service (IRS) denied the marital deduction and assessed an estate tax, a gift tax against the money passing from Quinto Jr. to Soila, and a penalty against Quinto Jr. for failure to file a gift-tax return. Quinto Jr. sued the tax commissioner (defendant), challenging his tax bill. The commissioner argued that both the estate and the assets passing between Quinto Jr. and Soila were taxable because Quinto Jr.’s disclaimer was not a qualified disclaimer under the tax code. The tax court ruled in favor of the tax commissioner. Quinto Jr. appealed.