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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.
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