Estate of Anna Mirowski, Deceased, Ginat W. Mirowski and Ariella Rosengard, Personal Representatives - Page 58




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          adequate and full consideration in the form of a proportionate              
          MFV interest.”  On the record before us, we reject respondent’s             
          contention.  Ms. Mirowski made two separate, albeit integrally              
          related, transfers of property that are at issue in this case,              
          namely, Ms. Mirowski’s transfers to MFV of certain assets on                
          September 1, 5, 6, and 7, 2001, and Ms. Mirowski’s respective               
          gifts of 16-percent interests in MFV to her daughters’ trusts on            
          September 7, 2001.  In return for Ms. Mirowski’s transfers to               
          MFV, Ms. Mirowski received and held 100 percent of the interests            
          in MFV.  In return for Ms. Mirowski’s respective gifts to her               
          daughters’ trusts, Ms. Mirowski received and held nothing.53                
               On the record before us, we find that Ms. Mirowski received            
          an interest in MFV proportionate to the value of the assets that            
          she transferred to it on September 1, 5, 6, and 7, 2001.  On that           
          record, we also find that Ms. Mirowski’s capital account was                
          properly credited with the assets that she transferred to it on             
          September 1, 5, 6, and 7, 2001, and that, in the event of a                 
          liquidation and dissolution of MFV, Ms. Mirowski had the right to           
          a distribution of property from MFV in accordance with her                  
          capital account.                                                            




               53Decedent’s personal representatives timely filed Form 709            
          for 2001 on behalf of decedent, in which those representatives              
          reported Ms. Mirowski’s gifts.  The parties have resolved their             
          dispute relating to the total value of those gifts.                         





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