72d CONGRESS . SESS . I. CH. 209 . J UNE 6, 19 32.
241 same provisions and limitations as in the case of a deficiency in a
M 00'E TAX t ax imp osed by this title (including the provisions in case of d elinqu ency in pa yment after noti ce and dema nd, t he pro visio ns authorizing distraint and proceedings in court for collection, and the provisions prohibiting claims and suits for refunds) (1) TRANSFEREES .-The lia bi lit y, at law or in equity, of a Liabiliti ees. transferee of property of a taxpayer, in respect of the tax (includ- T mnsf er ing inter est, additional amounts, and ad ditions to the ta x provided by law) imposed upon the taxpayer by this title . (2) FIDUCIARIES. The liability of a fiduciary under section Fiduciaries. 3467 of the Revised Statutes in respect of the payment of any .R . S., see. 3467, p.687. such tax from the estate of the taxpayer . Any such liabili ty may b e either as to t he amount of tax shown on Am ount determi ned . the return or as to any deficiency in tax . (b) PERIOD OF LIMITATION .-The period of limitation for assess- L imita tion peri ods . ment of any such liability of a transferee or fiduciary shall be as foll ows (1) In t he case of the l iability of an i nitial transferee of the fereel abie'ttal trans- property of the taxpayer,-within one year after the expiration of the period of limitation for assessment against the taxpayer; (2) In the case of the liability of a transferee of a transferee of f° Transferee of trans- the property of the taxpayer, within one year after the expiration of the period of limitation for assessment against the preceding transferee, but only if within three years after the expiration of the period o f limita tion for assessm ent again st the t axpayer; - except that if before the expiration of the period of limitation for Exception. One year after court the assessment of the liability of the transfere e, a court procee ding proceedings . for the collection of the tax or liability in respect thereof has been begun against the taxpayer or last preceding transferee, respec- tively,-then the period of limitation for assessment of the liability of the transferee s hall expire one year after the r eturn of executio n in the court proceeding (3) In the case of the liability of a fiduciary, not later than Fiduciary liable. one year after the liability arises or not later than the expiration of the period for collection of the tax in respect of which such liability arises, whichever is the later . e PERIOD FOR ASSESSMENT AGAINST TAXPAYER.-For the
Provisions on death (),
purposes of taxpayer or termi. of this section, if the taxpayer is deceased, or in the case of a corp o - nated corporation. ration, has terminated its existence, the period of limitation for assessment against the taxpayer shall be the period that would be in effect had the death or termination of existence not occurred .
Suspension of run- (d) SUSPENSION OF RUNNING OF STATUTE OF LIMITATIONS.-The ning of statute of running of the statute of limitations upon the assessment of the ma led ,aft er notice liability of a transferee or fiduciary shall, after the mailing to the Ante p x33 transferee or fiduciary of the notice provided for in section 272(a), be susp ended fo r the pe riod dur ing whic h the Co mmission er is pr o- hibited from m aking the assess ment in respect of the liability of the transferee or fiduciary (and in any event if a proceeding in respect Until decision of Board, etc. of the liabili ty is placed on the docket o the Board, until th e deci- sion of the Bo ard becomes fina l), and for 60 d ays thereafter .
Address for notice of (e) ADDRESS FOR NOTICE OF LIABILITY .-In the absence of notice to liability. the Com missione r under section 312(b) of the ex istence of a fid u- Pos t, p' 242. ciary relationship, notice of liability enforceable under this section in respect of a tax imposed by this title, if mailed to the person sub- ject to the liability at his last known address, shall be sufficient for the purposes of this title even if such person is deceased, or is under a legal disability, or, in the case of a corporation, has terminated its existence . 3031 °-33 1 B
