Ten-Year Statute of Limitations Applies to Transferees

In U.S. v. Mangiardi,the U.S. District Court for the Southern District of Florida ruled that thefour-year statute of limitations under tax code § 6901 does not apply to the collection from atransferee of unpaid federal estate taxes. Instead, the ten-year statute of limitations under § 6324 applies.

The defendant transferee in the case was the daughter of thedecedent and cotrustee of his will and trust. The court denied her motion to dismiss a collection action by the IRSseeking estate taxes in excess of $3 million.

See Daily Tax Report, Court Rules Estate Tax Statute ofLimitations Applies to Transferee, Bloomberg BNA, July 24, 2013.