CH. 71—TRANSFEREES AND FIDUCIARIES
841
CHAPTER 71—TRANSFEREES AND FIDUCIARIES Sec. Sec. Sec. Sec.
6901. 6902. 6903. 6904.
Transferred assets. Provisions of special application to transferees. Notice of fiduciary relationship. Prohibition of injunctions.
SEC. 6901. TRANSFERRED ASSETS. (a) M E T H O D OF COLLECTION.—The amounts of the following liabili-
ties shall, except as hereinafter in this section provided, be assessed, paid, and collected in the same manner and subject to the same provisions and limitations as in the case of the taxes with respect to which the liabilities were incurred: (1) INCOME, ESTATE, AND G-IFT TAXES.—
(A) TRANSFEREES,—The liability, a t law or in equity, of a transferee of property— (i) of a taxpayer in the case of a tax imposed by subtitle A (relating to income taxes), (ii) of a decedent in the case of a tax imposed by chapter 11 (relating to estate taxes), or (iii) of a donor in the case of a tax imposed by chapter 12 (relating to gift taxes), in respect of the tax imposed by subtitle A or B. (B) FIDUCIARIES.—The liability of a fiduciary under section 3467 of the Revised Statutes (31 U.S.C. 192) in respect of the payment of any tax described in subparagraph (A) from the estate of the taxpayer, the decedent, or the donor, as the case may be. (2) OTHER TAXES.—The liability, a t law or in equity of a trans-
feree of property of any person liable in respect of any tax imposed by this title (other than a tax imposed by subtitle A or B), b u t only if such liability arises on the liquidation of a partnership or corporation, or on a reorganization within the meaning of section 368 (a). (b) LIABILITY.—Any liability referred to in subsection (a) may be either as to the amount of tax shown on a return or as to any deficiency or underpayment of any tax. (c) PERIOD OP LIMITATIONS.—The period of limitations for assessment of any such liability of a transferee or a fiduciary shall be as follows: (1) INITIAL TRANSFEREE.—In the case of the liability of an initial transferee, within 1 year after the expiration of the period of limitation for assessment against the transferor; (2) TRANSFEREE OF TRANSFEREE.—In the case of the liability of a transferee of a transferee, within 1 year after the expiration of the period of limitation for assessment against the preceding transferee, b u t not more than 3 years after the expiration of the period of limitation for assessment against the initial transferor; except that if, before the expiration of the period of limitation for the assessment of the liability of the transferee, a court proceeding for the collection of the tax or liability in respect thereof has been begun 49012 "—54
56
§ 6901 (c)
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