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transfer, and Ms. Mirowski’s September 6 and 7, 2001 transfer to
MFV as Ms. Mirowski’s transfers to MFV.)
At no time did Ms. Mirowski contemplate forming MFV without
making a gift of an interest in MFV to each of her daughters’
trusts. Thus, on September 7, 2001, Ms. Mirowski made a gift of
a 16-percent interest in MFV to each of those trusts.15 Those
gifts were an integral part of Ms. Mirowski’s plan in forming and
transferring the bulk of her assets to MFV. (We shall sometimes
refer collectively to Ms. Mirowski’s respective gifts of 16-
percent interests in MFV to her daughters’ trusts as Ms.
Mirowski’s gifts.)
Ms. Mirowski understood that, based upon the value of the
assets that she transferred to MFV in exchange for a 100-percent
interest in MFV, her respective gifts of 16-percent interests in
MFV to her daughters’ trusts would result in a substantial gift
tax for 2001. Ms. Mirowski’s daughters were not aware of specif-
ically how Ms. Mirowski planned to pay the substantial gift tax
on those gifts. However, they were aware that Ms. Mirowski had
retained substantial personal assets that she did not transfer to
MFV, including over $3 million in cash and cash equivalents. Ms.
Mirowski’s daughters also knew that Ms. Mirowski anticipated
15Except for the respective gifts to her daughters’ trusts
that Ms. Mirowski made in 1992 and 1993, Ms. Mirowski made no
gifts to those trusts before her respective gifts on Sept. 7,
2001, of 16-percent interests in MFV.
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