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(A) Transferees.--The liability, at law or
in equity, of a transferee of property--
(i) of a taxpayer in the case of
a tax imposed by subtitle A (re-
lating to income taxes),
* * * * * * *
(h) Definition of Transferee.--As used in this
section, the term "transferee" includes donee, heir,
legatee, devisee, and distributee * * *.
The courts have recognized that section 6901 does not create
or define a substantive liability, but merely provides a pro-
cedure by which the Government may collect from a transferee of
property unpaid taxes owed by the transferor of the property.
Commissioner v. Stern, 357 U.S. 39, 42 (1958); Hagaman v. Com-
missioner, 100 T.C. 180, 183 (1993). The existence and extent of
a transferee's liability is determined under applicable State
law. See Commissioner v. Stern, supra at 42-45; Hagaman v.
Commissioner, supra at 183-185. The parties agree that the
applicable State law in these cases is the law of the State of
Florida. Petitioners argue, however, that under applicable
Florida law respondent must establish by clear and convincing
evidence, and not merely by a preponderance of the evidence, that
petitioners are liable as transferees. Respondent counters that
under applicable Florida law the standard of proof is a pre-
ponderance of the evidence. We agree with respondent. See
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