- 60 - Ms. Mirowski’s Gifts Transfer of Property by Ms. Mirowski Decedent’s estate acknowledges that Ms. Mirowski’s respec- tive gifts of 16-percent interests in MFV to her daughters’ trusts on September 7, 2001, were transfers of property. In light of that acknowledgment by decedent’s estate, we find that Ms. Mirowski’s gifts were transfers of property under section 2036(a). Transfer Other Than a Bona Fide Sale for an Adequate and Full Consideration in Money or Money’s Worth Decedent’s estate also acknowledges that Ms. Mirowski’s gifts were not bona fide sales for adequate and full consider- ation in money and money’s worth under section 2036(a). In light of that acknowledgment by decedent’s estate, we find that Ms. Mirowski’s gifts were not bona fide sales for adequate and full consideration in money or money’s worth under section 2036(a). Possession or Enjoyment of, or Right to Income From, the Property Transferred or Right To Designate the Persons Who Shall Possess or Enjoy the Property Transferred or the Income From Such Property The parties agree that an interest or a right described in section 2036(a)(1) and (2) is treated as having been retained if at the time of the transfer of property there was an express or implied agreement or understanding that the interest or right would later be conferred. See sec. 20.2036-1(a), Estate Tax Regs. They disagree over whether there was such an express orPage: Previous 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 NextLast modified: March 27, 2008