- 41 -
to themselves.32 In making that decision, MFV’s members had in
mind that those members will own collectively 100 percent of MFV,
in three equal shares, after decedent’s estate is closed.
For each of the years 1991 through 2001, Ms. Mirowski filed
Form 709, United States Gift (and Generation-Skipping Transfer)
Tax Return (Form 709), to reflect the substantial gifts that she
made during each of those years to, or for the benefit of, her
daughters, her grandchildren, and certain others.33 The aggre-
gate value of the gifts that Ms. Mirowski made during the years
1991 through 2001 was $24,715,921.34
On April 14, 2002, decedent’s estate paid estimated gift tax
of $11,750,623 with funds that MFV distributed to it. Thereaf-
ter, on or about July 20, 2002, decedent’s personal representa-
tives timely filed Form 709 for 2001 on behalf of decedent (2001
Form 709).35 Those representatives reported in that form Ms.
32In other words, MFV’s members agreed and decided that
during 2002 MFV should not make pro rata distributions to all of
the interest holders of MFV. Form 1065, U.S. Return of Partner-
ship Income (Form 1065), for MFV’s taxable year 2002 erroneously
reported for reasons not disclosed by the record that the distri-
butions that MFV made during that year were charged against the
respective capital accounts of MFV’s interest holders on virtu-
ally a pro rata basis.
33Ms. Mirowski also filed amended Form 709 for each of the
years 1992 and 1993.
34From 1991 through 2000, Ms. Mirowski made charitable gifts
totaling in excess of $12,500,000.
35The 2001 Form 709 erroneously reported for reasons not
(continued...)
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Last modified: March 27, 2008