Frank Armstrong, III, Transferee, et al. - Page 7




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                    (a) Liens for Estate Tax.--Except as otherwise                    
               provided in subsection (c)--                                           
                         (1) Upon Gross Estate.--Unless the                           
                    estate tax imposed by chapter 11 is sooner                        
                    paid in full, or becomes unenforceable by                         
                    reason of lapse of time, it shall be a lien                       
                    upon the gross estate of the decedent for 10                      
                    years from the date of death, except that                         
                    such part of the gross estate as is used for                      
                    the payment of charges against the estate and                     
                    expenses of its administration, allowed by                        
                    any court having jurisdiction thereof, shall                      
                    be divested of such lien.                                         
                         (2) Liability of Transferees and                             
                    Others.--If the estate tax imposed under                          
                    chapter 11 is not paid when due, then the                         
                    * * * transferee * * * who receives, or has                       
                    on the date of the decedent's death, property                     
                    included in the gross estate under sections                       
                    2034 to 2042, inclusive, to the extent of the                     
                    value, at the time of the decedent's death,                       
                    of such property, shall be personally liable                      
                    for such tax.  Any part of such property                          
                    transferred by (or transferred by a                               
                    transferee of) such * * * transferee * * * to                     
                    a purchaser or holder of a security interest                      
                    shall be divested of the lien provided in                         
                    paragraph (1) and a like lien shall then                          
                    attach to all the property of such * * *                          
                    transferee * * *, except any part transferred                     
                    to a purchaser or a holder of a security                          
                    interest.   [Emphasis added.]                                     
          In sum, in the event that a decedent's estate taxes are not paid            
          when due, section 6324(a)(1) imposes a 10-year lien on the gross            
          estate, and section 6324(a)(2) imposes personal liability upon              
          transferees of property included in the decedent's gross estate             
          under sections 2034 to 2042 and provides for the imposition of a            








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