Collapse to view only § 6901. Transferred assets
- § 6901. Transferred assets
- § 6902. Provisions of special application to transferees
- § 6903. Notice of fiduciary relationship
- § 6904. Prohibition of injunctions
- § 6905. Discharge of executor from personal liability for decedent’s income and gift taxes
§ 6901. Transferred assets
(a) Method of collection
The amounts of the following liabilities shall, except as hereinafter in this section provided, be assessed, paid, and collected in the same manner and subject to the same provisions and limitations as in the case of the taxes with respect to which the liabilities were incurred:
(1) Income, estate, and gift taxes
(A) Transferees
The liability, at law or in equity, of a transferee of property—
(i) of a taxpayer in the case of a tax imposed by subtitle A (relating to income taxes),
(ii) of a decedent in the case of a tax imposed by chapter 11 (relating to estate taxes), or
(iii) of a donor in the case of a tax imposed by chapter 12 (relating to gift taxes),
in respect of the tax imposed by subtitle A or B.
(B) Fiduciaries
(2) Other taxes
(b) Liability
(c) Period of limitations
The period of limitations for assessment of any such liability of a transferee or a fiduciary shall be as follows:
(1) Initial transferee
(2) Transferee of transferee
except that if, before the expiration of the period of limitation for the assessment of the liability of the transferee, a court proceeding for the collection of the tax or liability in respect thereof has been begun against the initial transferor or the last preceding transferee, respectively, then the period of limitation for assessment of the liability of the transferee shall expire 1 year after the return of execution in the court proceeding.
(3) Fiduciary
(d) Extension by agreement
(1) Extension of time for assessment
(2) Extension of time for credit or refund
(e) Period for assessment against transferor
(f) Suspension of running of period of limitations
(g) Address for notice of liability
(h) Definition of transferee
(i) Extension of time
(Aug. 16, 1954, ch. 736, 68A Stat. 841; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834; Pub. L. 97–258, § 3(f)(10), Sept. 13, 1982, 96 Stat. 1065; Pub. L. 115–141, div. U, title IV, § 401(a)(322), Mar. 23, 2018, 132 Stat. 1199.)
§ 6902. Provisions of special application to transferees
(a) Burden of proof
(b) Evidence
(Aug. 16, 1954, ch. 736, 68A Stat. 843;
§ 6903. Notice of fiduciary relationship
(a) Rights and obligations of fiduciary
(b) Manner of notice
(Aug. 16, 1954, ch. 736, 68A Stat. 843; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834.)
§ 6904. Prohibition of injunctions
For prohibition of suits to restrain enforcement of liability of transferee, or fiduciary, see section 7421(b).
(Aug. 16, 1954, ch. 736, 68A Stat. 843.)
§ 6905. Discharge of executor from personal liability for decedent’s income and gift taxes
(a) Discharge of liability
(b) Definition of executor
(c) Cross reference
(Added Pub. L. 91–614, title I, § 101(e)(1), Dec. 31, 1970, 84 Stat. 1837; amended Pub. L. 91–614, title I, § 101(f), Dec. 31, 1970, 84 Stat. 1838; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834.)