Estate of Anna Mirowski, Deceased, Ginat W. Mirowski and Ariella Rosengard, Personal Representatives - Page 56




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          members of the medical staff at that hospital who were responsi-            
          ble for treating Ms. Mirowski and the expectations of Ms.                   
          Mirowski and her daughters were that the treatment of her foot              
          ulcer would allow her to recover.                                           
               With respect to respondent’s contention (4), that contention           
          reads out of section 2036(a) in the case of any single-member LLC           
          the exception for a bona fide sale for an adequate and full                 
          consideration in money or money’s worth that Congress expressly             
          prescribed when it enacted that statute.  Respondent’s contention           
          (4) also ignores that Ms. Mirowski fully funded MFV; her daugh-             
          ters’ trusts did not contribute any assets to that company.                 
          Instead, each of those trusts was the recipient of a gift from              
          Ms. Mirowski consisting of a 16-percent interest in MFV.  We                
          reject respondent’s contention (4).                                         
               With respect to respondent’s contention (5), that contention           
          ignores our findings that at no time before September 10, 2001,             
          when Ms. Mirowski’s condition unexpectedly deteriorated signifi-            
          cantly, did Ms. Mirowski, her family, or her physicians expect              
          her to die and that consequently at no time did Ms. Mirowski and            
          her daughters discuss or anticipate the estate tax and similar              
          transfer taxes and the other estate obligations that would arise            
          only as a result of Ms. Mirowski’s death.51  Moreover, we reject            
          the suggestion of respondent that respondent’s contention (5) is            

               51See supra note 49.                                                   





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