52 STAT.] 75TH CONG. , 3D SESS.-CH. 289-MAY 28, 1938 SEC. 299. REMOVAL OF PROPERTY OR DEPARTURE FROM UNITED STATES. For additions to tax in case of leaving the United States or con- cealing property in such manner as to hinder collection of the tax, see section 146. 543 Removal of prop- erty or departure from United States. Additions to tax. Ante, p. 513. Supplement N-Claims against Transferees and Fiduciaries Claims against transferees and fiduci- SEC. 311 . TRANSFERRED ASSETS. Transferred assets. (a) METHODOF COLLECTION.-T he amounts of the following liabili- . lethod of collec- ties shall, except as hereinafter in this section provided, be assessed, ton 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 delinquency in payment after notice and demand, the provisions authorizing distrait and proceedings in court for collection, and the provisions prohibiting claims and suits for refunds): (1) TRANsFEREEs. -T he liability, at law or in equity, of a Transferees. 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) FIDUCIARIES. -The liability of a fiduciary under section Fidciaries 3467 of the Revised Statutes in respect of the payment of any R. S. §347. such tax from the estate of the taxpayer. 31. Any such liability may be either as to the amount of tax shown on the return or as to any deficiency in tax. (b) PERIOD OF LIMITAION.- The period of limitation for assess- Periodoflimitation. 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- property of the taxpayer,-within one year after the expiration f e reelia le . of the period of limitation for assessment against the taxpayer; (2) In the case of the liability of a transferee of a trans- When transferee of feree of the property of the taxpayer,-within one year after a trasereeable the expiration of the period of limitation for assessment against the preceding transferee, but only if within three years after the expiration of the period of limitation for assessment against the taxpayer;- except that if before the expiration of the period of limitation for Exception. 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 taxpayer or last preceding transferee, respec- tively,-then the period of limitation for assessment of the liability of the transferee shall expire one year after the return of execution in the court proceeding. (3) In the case of the liability of a fiduciary,-not later than lb he n fiduiary one year after the liability arises or not later than the expira- tion of the period for collection of the tax in respect of which such liability arises, whichever is the later; (4) Where before the expiration of the time prescribed in OTfornasssement paragraph (1), (2), or (3) for the assessment of the liability, ol ty both the Commissioner and the transferee or fiduciary have con- sented in writing to its assessment after such time, the liability may be assessed at any time prior to the expiration of the period agreed upon. The period so agreed upon may be extended by subsequent agreements in writing made before the expiration of the period previously agreed upon. (c) PERIOD FOR ASSESSMErNT AGAINST TAXPAYE-For the purposes Period forasse- of this section, if the taxpayer is deceased, or in the case of a cor- payesr. gin st ta x- poration, has terminated its existence, the period of limitation for
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