Page:United States Statutes at Large Volume 49 Part 1.djvu/1774

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74TH C ONGRESS . SESS. II. CH. 690. JUNE 22, 1936 .

1729 of the amount collected in excess of the amount of the jeopardy assessment, interest as provided in section 292 . If the amount Additional, i f included in th e notice and dema nd from the colle ctor under sectio n amo unt of d efic ienc y not paid in full . 273 (i) is not paid in full within ten days after such notice and demand, then there shall be collected, as part of the tax, interest upon the unpaid amount at the rate of 6 per cen tum per an num (or, for any period the estate of the taxpayer is held by a fiduciary appointed by any court of competent jurisdiction or by will, at the rate of 6 per centum per annum) from the date of such notice and demand until i t is paid . SEC. 298. BANKRUPTCY AND RECEIVERSHIPS.

Bankruptcy and re- ceiverships. If the unpaid portion of the claim allowed in a bankruptcy or interest, if not paid receivership proceeding, as provided in section 274, is not paid in on Anfe demand . , p.1725. full within ten days from the date of notice and demand from the collector, then there shall be collected as a part of such amount interest upon the unpaid portion thereof at the rate of 6 per centum per annum from the date of such notice and demand until payment . SEC. 299. REM OVA L OF PRO PER TY OR DEPARTURE FROM UNITED Removal of prop- ST ATES .

ert y , etc . For additions to tax in case of leaving the United States or Addi tions to tax for, concealing property in such manner as to hinder collection of the etinre, p. 1703. tax, see section 146 . Supplement N-Claims against Transferees and Fiduciaries

Clai ms agains t trans- ferees and fiduciaries . SEC. 311. TRANSFERRED A SSETS .

Tran sferred a ssets . (a) METHOD OF COLT .E CTION .-The amounts of the following ha- Me thod of co llect ion . bilities shall , except as herei nafter in this se ction provided, b e 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 case of'delin- quency in payment after notice and demand, the provisions author- izing distraint and proceedings in court for collection, and the provisions prohibiting claims and suits for refunds) ( 1) TRANSF EREES .-The liability, at law or in equity, of a trans- Transferees. feree 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) FrDUCIARIEs .-The liability of a fiduciary under section Fiduciaries . 3467 of the Revised Statutes in respect of the payment of any such u . s . c ., p . 1367. tax from the estate of the taxpayer . Any such liability may be either as to the amount of tax shown on Determination of amount . the return or as to any deficiency in tax . (b) PERIOD OF LIMITATION .-The period of limitation for assess- ment of any such liability of a transferee or fiduciary shall be as follows (1) In the case of the liability of an initial transferee of the When initial trans- fer ee liable . property of the taxpayer,-within one year after the expiration of the period of limitation for assessment against the taxpayer ; In the case of the liability of a transferee of a transferee Transferee ofa traps- (2)

fer ee liable . of the property of the taxpayer,-within one year after the expira- tion of the period of limitation for assessment against the preced- ing transferee, but only if within three years after the expiration of the period of limitation for assessment against the taxpayer

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except that if before the expiration of the period of limitation for Exce ption . the assessment of the liability of the transferee, a court proceeding for the collection of the tax or liability in respect thereof has been 104019'-36-109