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Transferee Liability
The IRS was not barred by the statute of limitation nor the doctrine of laches in assessing estate tax liability upon a transferee of an estate that had not paid $11 million of estate tax. The estate had received a timely notice of deficiency and the period of limitations was suspended from the time the notice of deficiency was mailed until 60 days after the Tax Court's decision became final-see §6503(a)(1). Laches did not apply because there were no inexcusable delays on the part of the IRS. Moreover, the transferee did not have "clean hands" in that he was aware of the estate's tax liability when he received distributions from the estate.
Source: Fridovich, TC Memo. 2001-32, 81 TCM 1143
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