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Ms. Mirowski’s respective gifts of 16-percent interests in MFV to
her daughters’ trusts:74
(1) Was there a transfer of property by Ms. Mirowski during
the three-year period ending on the date of her death?
(2) If there was a transfer of property by Ms. Mirowski
during the three-year period ending on the date of her death,
would the value of any such property have been included in her
gross estate under section 2036 or 203875 if the property
transferred by Ms. Mirowski had been retained by her on the date
of her death?
Transfer of Property During the Three-Year
Period Ending on the Date of Death
Decedent’s estate acknowledges that Ms. Mirowski’s
respective gifts of 16-percent interests in MFV to her daughters’
trusts on September 7, 2001, were transfers of property during
the three-year period ending on the date of her death. In light
73(...continued)
been so included.
74In advancing respondent’s alternative argument under sec.
2035(a), respondent does not assert that during the three-year
period ending on the date of Ms. Mirowski’s death Ms. Mirowski
relinquished a power with respect to the respective 16-percent
interests in MFV that she gave to her daughters’ trusts.
Therefore, our discussion of sec. 2035(a) is limited to Ms.
Mirowski’s gifts.
75In advancing respondent’s alternative argument under sec.
2035(a), respondent does not assert that Ms. Mirowski’s transfers
to MFV are includible in her gross estate under sec. 2037 or
2042. Therefore, our discussion of sec. 2035(a) is limited to
secs. 2036 and 2038.
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Last modified: March 27, 2008