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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. Although Congress later determined that it
was redundant to impose a lien on a decedent's property in the
hands of a transferee under section 827(b) given the imposition
of an identical lien on a decedent's property prescribed in
section 827(a) (the predecessor to section 6324(a)(1)), the
second sentence of section 6324(a)(2) continues to provide for a
lien on a transferee's separate property. Despite the difference
in the remedies provided under the first and second sentences of
section 6324(a)(2), we see no basis for concluding that Congress
intended to distinguish between the two in the application of
section 2035(d)(3)(C).
The legislative history underlying section 2035(d)(3)(C)
does not persuade us to hold otherwise. Although H. Rept. 97-
201, supra, suggests that the House may have viewed section
2035(d)(3)(C) primarily as a means to impose a lien upon property
in aid of the collection of unpaid estate taxes, the related
conference report explains the addition of section 2035(d)(3)(C)
as follows: "[A]ll gifts made within 3 years of death are
included [in the gross estate] for purposes of * * * estate tax
liens (subchapter C of chapter 64)." H. Conf. Rept. 97-215, at
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