Estate of Anna Mirowski, Deceased, Ginat W. Mirowski and Ariella Rosengard, Personal Representatives - Page 2




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          the Estate of Anna Mirowski (decedent’s estate).1                           
               The issues remaining for decision are whether any of the               
          assets owned by Mirowski Family Ventures, L.L.C. (MFV), are                 
          includible in the gross estate of Anna Mirowski (Ms. Mirowski or            
          decedent) under section 2036(a),2 2038(a)(1), or 2035(a).  We               
          hold that none of the assets owned by MFV is includible in                  
          decedent’s gross estate under any of those sections.                        
                                  FINDINGS OF FACT                                    
               Many of the facts have been stipulated and are so found.               
               Ms. Mirowski was a resident of Owings Mills, Maryland, at              
          the time of her death on September 11, 2001.  Ginat W. Mirowski             
          (Ginat Mirowski) and Ariella Rosengard, the personal representa-            
          tives of decedent’s estate and two of decedent’s three                      
          daughters,3 resided in Carmel, Indiana, and the United Kingdom,             
          respectively, at the time they filed the petition in this case.             
               Ms. Mirowski, who was born on December 22, 1927, was the               
          youngest of three daughters.  Ms. Mirowski’s parents, who were              


               1Respondent determined a deficiency of $4,769,233 in dece-             
          dent’s Federal gift tax (gift tax) for her taxable year 2001.               
          The parties settled all the gift tax issues in this case.                   
               2Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect on the date of Ms. Mirowski’s           
          death.  All Rule references are to the Tax Court Rules of Prac-             
          tice and Procedure.                                                         
               3Ginat Mirowski is the oldest of decedent’s daughters,                 
          Ariella Rosengard is the next oldest daughter, and Doris Frydman            
          is the youngest daughter.                                                   





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