- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008