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Mirowski’s gift on September 7, 2001, to each of her daughters’
trusts of a 16-percent interest in MFV and valued each of those
gifts at $5,700,000.36 In the 2001 Form 709, decedent’s personal
representatives reported gift tax for 2001 of $9,729,280, which
resulted in a credit to decedent’s estate of $2,021,343.37
Decedent’s estate timely filed Form 706, United States
Estate (and Generation-Skipping Transfer) Tax Return. Form 706
showed estate tax of $14,119,863.13, which decedent’s estate paid
on June 10, 2002, with funds that MFV distributed to it.38
Respondent issued to decedent’s estate a notice of defi-
ciency, in which respondent determined an estate tax deficiency
of $14,243,208.37. In support of that deficiency determination,
respondent determined, inter alia, to increase decedent’s gross
35(...continued)
disclosed by the record that Ms. Mirowski made gifts of furniture
on Sept. 10, 2001, to Ariella Rosengard valued at $25,500 and
gifts of jewelry on the same date to Doris Frydman valued at
$45,295. Ms. Mirowski did not in fact make those gifts on Sept.
10, 2001, as reported in the 2001 Form 709. When Ms. Mirowski
purchased the items of furniture and jewelry in question, she had
her daughters Ariella Rosengard and Doris Frydman in mind and
intended to make those respective gifts to them during her life.
36In the parties’ stipulation of settled issues, the parties
agreed that the value of the 16-percent interest in MFV that Ms.
Mirowski gave to each of her daughters’ trusts is $6,810,350.
See supra note 1.
37See supra notes 1 and 36.
38The liability shown in the Maryland estate tax return that
decedent’s estate filed was $5,040,815.64, which decedent’s
estate paid on June 10, 2002, with funds that MFV distributed to
it. See supra note 31.
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Last modified: March 27, 2008