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of that acknowledgment by decedent’s estate, we find that Ms.
Mirowski’s gifts were transfers of property during the three-year
period ending on the date of her death under section 2035(a).
Property Transferred Otherwise Includible in Gross Estate
We have found that sections 2036(a) and 2038(a)(1) do not
apply to Ms. Mirowski’s transfers to MFV. A fortiori, section
2035(a) could not apply, and we hold that that section does not
apply, to Ms. Mirowski’s respective gifts of 16-percent interests
in MFV to her daughters’ trusts.
Based upon our examination of the entire record before us
and our holdings under sections 2036(a) and 2038(a)(1) with
respect to Ms. Mirowski’s transfers to MFV, we hold that section
2035(a) does not apply to Ms. Mirowski’s respective gifts of 16-
percent interests in MFV to her daughters’ trusts.
We have considered all of the parties’ respective
contentions and arguments that are not discussed herein, and we
find them to be without merit, irrelevant, and/or moot.
To reflect the foregoing and the concessions of the parties,
Decision will be entered
under Rule 155.
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Last modified: March 27, 2008