Mary A. Saigh, a.k.a. Mary Saigh, Transferee - Page 6

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          later than the date notice and demand for the tax is made by the            
          Secretary).”1  Section 6601(e)(1) further provides that the                 
          interest prescribed under this section “shall be assessed,                  
          collected, and paid in the same manner as taxes.”                           
               Section 6324(a)(2) provides, in relevant part:                         
               If the estate tax imposed by chapter 11 is not paid when               
               due, then the * * * transferee * * *, who receives, or has             
               on the date of the decedent’s death, property included in              
               the gross estate under sections 2034 to 2042, inclusive, to            
               the extent of the value, at the time of the decedent’s                 
               death, of such property, shall be personally liable for such           
               tax.  * * *                                                            
          That is, if an estate tax is unpaid when due, then certain                  
          transferees, who receive property includable in the gross estate            
          under sections 2034 to 2042, are personally liable for the unpaid           
          tax to the extent of the value of such property at the time of              
          the decedent’s death.  Sec. 6324(a)(2); see Armstrong v.                    
          Commissioner, 114 T.C. 94, 98 (2000).                                       
               Further, section 6901(a) provides that such liabilities of             
          the transferee shall be assessed, paid, and collected in the same           
          manner as the taxes with respect to which the liabilities were              
          incurred.  Thus, section 6901(a) sets forth the procedures to be            
          followed in transferee liability cases; the existence and extent            
          of a transferee’s substantive liability are established under               



               1 Sec. 6601(b) does not otherwise specify the last date for            
          payment of a transferee’s liability for unpaid estate tax.                  





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