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receiving as an interest holder in MFV future income of millions
of dollars a year attributable to royalty payments under the ICD
patents license agreement. In addition, Ms. Mirowski’s daughters
believed that Ms. Mirowski could have borrowed against her
interest in MFV in order to pay the substantial gift tax liabil-
ity attributable to her respective gifts to her daughters’ trusts
of 16-percent interests in MFV. At no time before Ms. Mirowski’s
death did the members of MFV have any express or unwritten
agreement or understanding to distribute assets of MFV in order
to pay that gift tax liability.
After the respective gifts to her daughters’ trusts of 16-
percent interests in MFV, Ms. Mirowski held a 52-percent inter-
est, and each of those trusts held a 16-percent interest, in MFV.
As discussed above, MFV held a 51.09-percent interest under the
ICD patents license agreement after Ms. Mirowski’s September 1,
2001 transfer to MFV. Each of the daughters’ trusts continued to
hold a 7.2616-percent interest under the ICD patents license
agreement after Ms. Mirowski made a gift of a 16-percent interest
in MFV to each of those trusts.
After Ms. Mirowski’s transfers to MFV, she retained in her
individual name the following assets (personal assets) valued at
approximately $7,598,000: Ms. Mirowski’s home valued at
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Last modified: March 27, 2008