- 79 - Transfer Other Than a Bona Fide Sale for an Adequate and Full Consideration in Money or Money’s Worth Like section 2036(a), section 2038(a)(1) excepts from its application any transfer of property otherwise subject to that section which is a “bona fide sale for an adequate and full consideration in money or money’s worth”. The respective exceptions in sections 2036(a) and 2038(a)(1) have the same meaning. Based upon our examination of the entire record before us and for the reasons stated above with respect to our finding that Ms. Mirowski’s transfers to MFV were bona fide sales for adequate and full consideration in money or money’s worth under section 2036(a), we find that Ms. Mirowski’s transfers to MFV were bona fide sales for adequate and full consideration in money or money’s worth under section 2038(a)(1). Based upon that examination and for those reasons, we further find that the exception under section 2038(a)(1) for a bona fide sale for an adequate and full consideration in money or money’s worth applies to Ms. Mirowski’s transfers to MFV. Power To Alter, Amend, Revoke, or Terminate the Enjoyment of the Property Transferred or Relinquishment of Any Such Power During the Three-Year Period Ending on the Date of Death We have found that Ms. Mirowski’s transfers to MFV were bona fide sales for adequate and full consideration in money or money’s worth under section 2038(a)(1). Consequently, we need not, and we shall not, address the factual issues presented underPage: Previous 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 NextLast modified: March 27, 2008