§ 141. Transferees. (a) General.--The liability, at law or in equity,
of a transferee of property of a taxpayer for any tax, additions to tax,
penalty or interest due the director of finance under this title, shall
be assessed, paid, and collected in the same manner and subject to the
same provisions and limitations as in the case of the tax to which the
liability relates, except that the period of limitations for assessment
against the transferee shall be extended by one year for each successive
transfer, in order, from the original taxpayer to the transferee
involved, but not by more than three years in the aggregate. The term
"transferee" includes donee, heir, legatee, devisee and distributee.

(b) Exceptions.--(1) If before the expiration of the period of
limitations for assessment of liability of the transferee, a claim has
been filed by the director of finance in any court against the original
taxpayer or the last preceding transferee based upon the liability of
the original taxpayer, then the period of limitation for assessment of
liability of the transferee shall in no event expire prior to one year
after such claim has been finally allowed, disallowed or otherwise
disposed of.

(2) If, before the expiration of the time prescribed in subdivision
(a) or the immediately preceding paragraph of this subdivision for the
assessment of the liability, the director of finance and the transferee
have both consented 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. For the purpose of determining the period
of limitation on credit or refund to the transferee of overpayments of
tax made by such transferee or overpayments of tax made by the
transferor as to which the transferee is legally entitled to credit or
refund, such agreement and any extension thereof shall be deemed an
agreement and extension thereof referred to in subdivision (b) of
section one hundred thirty-five. If the agreement is executed after the
expiration of the period of limitation for assessment against the
original taxpayer, then in applying the limitations under subdivision
(b) of section one hundred thirty-five on the amount of the credit or
refund, the periods specified in subdivision (a) of section one hundred
thirty-five shall be increased by the period from the date of such
expiration to the date of the agreement.

(c) Deceased transferor.--If any person is deceased, the period of
limitation for assessment against him shall be the period that would be
in effect if he had lived.

(d) Evidence.--Notwithstanding the provisions of subdivision (e) of
section one hundred forty-five the director of finance shall use his
powers to make available to the transferee evidence necessary to enable
the transferee to determine the liability of the original taxpayer and
of any preceding transferees, but without undue hardship to the original
taxpayer or preceding transferee. See subdivision (e) of section one
hundred thirty-seven for rule as to burden of proof.