- 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 Next
Last modified: March 27, 2008