- 73 - license agreement that she expected MFV to receive, and (3) borrowed against (a) the personal assets that she retained and did not transfer to MFV and (b) her 52-percent interest in MFV,65 see Md. Code Ann., Corps. & Assns. sec. 4A-602 (West 2008); Md. Code Ann., Com. Law sec. 1-201(37) (West 2008). In addition, as also discussed above, we have found that at no time before September 10, 2001, when Ms. Mirowski’s condition unexpectedly deteriorated significantly, did Ms. Mirowski, her daughters, or her physicians expect her to die and that conse- quently 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.66 In 2002, after Ms. Mirowski died, MFV distributed over $36 million to decedent’s estate in order for the estate to pay Federal and State transfer taxes, legal fees, and other estate obligations. At the time in 2002 when MFV made those distribu- tions to decedent’s estate, MFV’s members (i.e., the daughters’ trusts),67 through their respective trustees (i.e., Ms. 65See supra note 48. 66As discussed supra note 49, the estate tax that would arise only as a result of Ms. Mirowski’s death would not have been the obligation of Ms. Mirowski. 67The daughters’ trusts were the remaining members of MFV after Ms. Mirowski’s death.Page: Previous 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 NextLast modified: March 27, 2008