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(1998). There, this Court held that “respondent is not bound by
the limitations period in California’s UFTA in seeking to assert
or assess transferee liability against * * * [the transferee]
under section 6901." Id. at 190. Rather, “section 6901(c) is
the applicable limitations period to which respondent is bound in
asserting transferee liability”. Id. Given this precedent and
for the reasons stated therein, we likewise hold here that
respondent has issued a timely notice of transferee liability.
B. Transferee Liability
1. Necessity for Deficiency Determination or Assessment
Against Transferor
Preliminary to our discussion of whether respondent has
established the substantive elements of transferee liability, we
address whether, as petitioner appears to contend, the purported
lack of a valid deficiency notice or assessment against the
transferor in any way inhibits respondent’s determinations of
liability for taxes, or additions to tax, against a transferee.
To answer this inquiry in the affirmative, however, would be
contrary both to congressional intent as evidenced by legislative
history and to existing case law.
Legislative history deals explicitly with the procedural
requirement of a notice of deficiency in contexts involving
transferee liability:
Section 274(a) [predecessor of sections 6212 and
6213] requires notice of a deficiency in a tax to be
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