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Significantly, each of the subparagraphs in section 2035(d)(3)
contains parenthetical language. In each case, the parenthetical
language is simply an abbreviation of the title of the section or
subchapter referred to therein. For example, section
2035(d)(3)(A) provides that gifts made within 3 years of death
shall be included in the gross estate for purposes of "section
303(b)(relating to distributions in redemption of stock to pay
death taxes)". Like the parenthetical language, the title of
section 303 is "Distributions In Redemption Of Stock To Pay Death
Taxes." Similarly, the parenthetical language in section
2035(d)(3)(C), "(relating to lien for taxes)", is simply a
reference to the title for subchapter C of chapter 64--"Lien for
Taxes". Thus, we reject petitioners' argument that the
parenthetical language limits the applicability of section
2035(d)(3)(C) to any specific provisions within subchapter C of
chapter 64.
Moreover, section 6324(a)(2) is properly characterized as a
lien provision. Section 827(b) of the Internal Revenue Code of
1939, a predecessor to section 6324(a)(2), imposed personal
liability on a transferee of property included in a decedent's
gross estate and provided for the imposition of a lien on: (1)
The decedent's property in the hands of the transferee; and (2) a
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