- 46 - possession or the enjoyment of, or the right to the income from, the property transferred within the meaning of section 2036(a)(1) or (b) did she retain, either alone or in conjunction with any person, the right to designate the persons who shall possess or enjoy the property transferred or the income therefrom within the meaning of section 2036(a)(2)? Ms. Mirowski’s Transfers to MFV Transfer of Property by Ms. Mirowski Decedent’s estate acknowledges that Ms. Mirowski made transfers of property to MFV on September 1, 5, 6, and 7, 2001. In light of that acknowledgment by decedent’s estate, we find that Ms. Mirowski’s transfers to MFV were transfers of property under section 2036(a). Transfer Other Than a Bona Fide Sale for an Adequate and Full Consideration in Money or Money’s Worth Section 2036(a) excepts from its application any transfer of property otherwise subject to that section which is a “bona fide sale for an adequate and full consideration in money or money’s worth”. The foregoing exception is limited to a transfer of property where the transferor “has received benefit in full consideration in a genuine arm’s length transaction”. Estate of Goetchius v. Commissioner, 17 T.C. 495, 503 (1951). More re- cently, we held that the exception in section 2036(a) for a bona fide sale for an adequate and full consideration in money or money’s worth is satisfied in the context of a family limitedPage: Previous 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 NextLast modified: March 27, 2008