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lien on the transferee's separate property in the event the
transferee should transfer any part of such property received
from the decedent.
Section 6324(a)(2) provides that a transferee's liability
for unpaid estate taxes is limited to the value of the property
that is included in the decedent's gross estate under sections
2034 to 2042 and transferred to the transferee as measured at the
time of the decedent's death. However, a transferee's liability
is not conditioned on either the exhaustion of remedies for
collection against the estate or the estate's insolvency. See
Schuster v. Commissioner, 312 F.2d at 315; Equitable Life
Assurance Society v. Commissioner, 19 T.C. 264, 269 (1952);
Estate of Callahan v. Commissioner, T.C. Memo. 1981-357.
Relying on the portion of section 6901(a) which states that
the Commissioner may only assess and collect an estate tax
deficiency from a transferee "in the same manner and subject to
the same provisions and limitations as in the case of the taxes
with respect to which the liabilities were incurred", petitioners
first contend that they are not liable for the Armstrong estate
tax deficiency inasmuch as the stock that decedent transferred to
them was not the source of the deficiency. Petitioners reason
that if there is no estate tax directly related to decedent's
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