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constraints of State law would be an even greater burden,
particularly where, as in the case herein, the transferor is
delinquent in filing its tax return.
Additionally, the Supreme Court has consistently held that,
although State law is controlling as to the nature and extent of
the property rights in applying a Federal revenue act, Federal law
determines the consequences of those rights. United States v.
National Bank of Commerce, 472 U.S. 713, 722-723 (1985); Aquilino
v. United States, 363 U.S. 509, 513 (1960). "'[O]nce it has been
determined that state law creates sufficient interests in the * *
* [taxpayer] to satisfy the requirements of * * * [the statute],
state law is inoperative,' and the tax consequences thenceforth are
dictated by federal law." United States v. National Bank of
Commerce, supra at 722 (quoting United States v. Bess, 357 U.S. 51,
56-57 (1958)).
In the situation before us we are concerned only with whether
the Alhambra property was fraudulently conveyed to petitioner under
California's UFTA; we are not concerned with whether the UFTA would
permit the Federal Government to assess petitioner for transferee
liability as a result of the fraudulent conveyance. The latter
issue, including the time within which to assess, is resolved by
Federal revenue law, not State property law. See sec. 6901.
Thus, we hold that respondent is not bound by the limitations
period in California's UFTA in seeking to assert or assess
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