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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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Last modified: May 25, 2011