- 58 - 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.Page: Previous 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 NextLast modified: March 27, 2008