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assessment in docket No. 42224-85. See secs. 6501, 6503.
Pursuant to section 6901(c)(1), the period of limitations for
assessment of a liability against an initial transferee is 1 year
after the expiration of the period of limitations for assessment
against the transferor. See, e.g., Bresson v. Commissioner, 111
T.C. 172 (1998), affd. 213 F.3d 1173 (9th Cir. 2000). Here, as
noted, the period of limitations for assessment of the liability
did not expire with respect to the estate until March 2, 1997, and
with respect to petitioner before March 2, 1998, which was 70 days
after the date (December 22, 1997) the notice of transferee
liability was sent to petitioner. Consequently, the notice of
transferee liability to petitioner was timely, and the statute of
limitations did not bar respondent from assessment and collection
of the $1,118,621 estate tax liability against petitioner.
We now turn to petitioner’s alternative argument that the
doctrine of laches operates to preclude respondent’s assessment and
collection of the liability owed by petitioner. The doctrine of
laches bars a claim when the following three elements are present:
(1) There was a delay in asserting a right or a claim; (2) the
delay was inexcusable; and (3) there is undue prejudice to the
party against whom the claim is asserted. See, e.g., Kason Indus.,
Inc. v. Component Hardware Group, Inc., 120 F.3d 1199, 1203 (11th
Cir. 1997); Albertson v. T.J. Stevenson & Co., 749 F.2d 223, 233
(5th Cir. 1984). The doctrine of laches can be raised only by one
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