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form MFV. Although Ms. Mirowski understood that certain tax
benefits could result from forming MFV, those potential tax
benefits were not the most significant factor in her decision to
form MFV. To the contrary, Ms. Mirowski had the following
legitimate and significant nontax purposes for forming, and
transferring the bulk of her assets to, MFV: (1) Joint manage-
ment of the family’s assets by her daughters and eventually her
grandchildren; (2) maintenance of the bulk of the family’s assets
in a single pool of assets in order to allow for investment
opportunities that would not be available if Ms. Mirowski were to
make a separate gift of a portion of her assets to each of her
daughters or to each of her daughters’ trusts; and (3) providing
for each of her daughters and eventually each of her grandchil-
dren on an equal basis.
With respect to Ms. Mirowski’s purpose in forming MFV of
having her daughters, and eventually her grandchildren, jointly
manage the family’s assets, that purpose was rooted in Ms.
Mirowski’s formative years in Lyon, where her family worked
together in the family business.9 Ms. Mirowski valued the family
cohesiveness that joint management of a family business can
foster. Although Ms. Mirowski was aware that her daughter
9After Ms. Mirowski left France and moved to Israel and
ultimately to the United States with Dr. Mirowski and their
daughters, Ms. Mirowski was unable to continue working together
with her family in the family business in France, which she
regretted very much.
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Last modified: March 27, 2008