Liability of transferee of assets

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4395243-952.  Liability of transferee of assets

A.  The amounts of the following liabilities, except as hereinafter provided in this section and section 43 953, shall be assessed, collected and paid in the same manner and subject to the same provisions and limitations as in the case of a deficiency in a tax imposed by this title, including the provisions in the case of a delinquency in payment after notice and demand, the provisions authorizing proceeding in court for collection and the provisions prohibiting claims and suits for refunds:

1.  The liability, at law or in equity, of a transferee of property of a taxpayer, in respect of the tax, including interest, additional amounts and additions to the tax provided by law, imposed upon the taxpayer by this title.

2.  The liability of a fiduciary under this title, in respect of the payment of any such tax from the estate of the taxpayer.

B.  Any such liability may be either as to the amount of tax shown on the return or as to any deficiency in tax. 43952

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