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stock transfers, respondent is barred from attempting to collect
such taxes from them.
Petitioners' reliance on section 6901(a) as the basis for
defining the scope of their liability as transferees is
misplaced. As previously discussed, section 6901(h) defines a
transferee in pertinent part as "any person who, under section
6324(a)(2), is personally liable for any part of such tax."
Section 6324(a) in turn establishes the existence and extent of a
transferee's substantive liability. See Schuster v.
Commissioner, supra. In contrast, section 6901(a) merely
prescribes the procedures that respondent must follow in
assessing and collecting taxes from transferees under that
section. See id. Thus, although section 6901(a) provides that
respondent must follow the normal deficiency procedures before
assessing and collecting estate taxes from a transferee, the
provision does not define or otherwise restrict a transferee's
substantive liability as petitioners contend.
Petitioners argue in the alternative that they are not
liable as transferees under section 6324(a)(2) on the ground that
they did not receive property that is includable in the gross
estate pursuant to sections 2034 through 2042. Petitioners
emphasize that the estate tax deficiency is attributable solely
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