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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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