- 56 - 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.Page: Previous 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 NextLast modified: March 27, 2008