860
SEVENTIETH CONGRESS . SEss . I. CH. 852 . 1028 . INC OME TAX SEC. 299. REMOVAL OF PROPERTY OR DEPARTURE FROM UNITED Remo val ofproper ty.
STATES . Additions to tax for,
For additions to tax in case of leaving the United States or con- et ante, p . 836.
cealing property in such manner as to hinder collection of the tax, see section 147 . Claims a gainst trans- ferees and
Supplement N-Claims against Transferees and Fidu- ciaries Transferred assets.'* SEC. 311 . TRAN SFE RRE D ASSETS . Me tax Met hod ofr collection to de- (a ) Me thod of c ollec tion .-The amounts of the followin g liabil ities ficiency~ - shall, except as hereinafter in this section provided, be assessed, collected, and paid in the same manner and subject to the same pro- visions and limitations as in the case of a deficiency in a tax imposed by this title (including the provisions in case of delinquency in pay- ment after notice and demand, the provisions authorizing distraint and proceedings in court for collection, and the provisions prohibit- ing claims and suits for refunds) Transferees.
(1) TRANSFEREES.-The liability, at law or in equity, of a transferee of property of a taxpayer, in respect of the tax (including interest, additional amounts, and additions to the tax provided by law) imposed upon the taxpayer by this title . Fiduciaries. (2) FIDUCIARIES .-The liability of a fiduciary under section 68 7. S ., sec. 3467, p:
3467 of the Revised Statutes in respect o f the payment of any such tax from the estate of the taxpayer . aDunr rminatlenof Any such liabi lity may be either as to the amount of t ax shown on the return or as to any deficiency in tax . Limitation periods.
(b) Peri od o f lim itat ion .-The period of limitation for assessment one year after tat ° of any such liability of a transferee or fiduciary shall be as follows : payer's a ssessment .
(1) In the case of the liability of an initial transferee of the property of the taxpayer,-within one year after the expiration Transferee of a trans-
of the peri od of li mitation for ass essment against the taxp ayer ; feree, within one year
(2) In the case of the liability of a transferee of a transferee after period of first transferee . of the prop erty of the taxp ayer,-wi thin one year af ter the expi- ration of the period of limitation for assessment agai nst the preceding transferee, but only if within three years after the expiration of the period of limitation for assessment against the One year af ter court
taxpayer ;- proceedings. except that if before the expiration of the period of limitation for the assessment of the liability of the transferee, a court pro- ceeding for the collection of the tax or liability in respect thereof has been begun against the taxpayer or last preceding transferee, respectively,-then the period of limitation for assessment of the liability of the transferee shall expire one year after the return of execut ion in t he court proceed ing . after Fiduciary, liability arises. ye ar
(3) In the case of the liability of a . fiduciary, not later than . one year after the liability arises or not later than the expira- tion of the period f or collec tion of the tax in respe ct of wh ich such liability arises, whichever is the later . Provision for death taxpayer or terminated (c) Period for assessment against taxpayer .-For the purposes corporation° of this section, if the taxpayer is deceased, or in the case of a cor- poratio n, has t erminate d its ex istence, the per iod of l imitatio n for assessm ent agai nst the taxpayer shall b e the pe riod tha t would be in effect had the death or termination of existence not occurred . Suspe nsio n of run- nin e of statute of limi - (d) Suspension of running of statute of limitations .-The running tatio n, after notice of the statute of limitations upon the assessment of the liabil- mailed, etc. Ante, p. ssz.
ity of a transferee or fiduciary shall, after the mailing to the trans- feree or fiduciary of the notice provided for in section 272(a),
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