§ 84. Transferees. 1. 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 part or under
the named parts, 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, in case of successive
transfers, donee, heir, legatee, devisee, distributee, and successor by
merger, consolidation or other reorganization.

2. Exceptions.--

(a) 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.

(b) If, before the expiration of the time prescribed in subdivision
one 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 or 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 two of
section seventy-eight. 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 two of
section seventy-eight on the amount of the credit or refund, the periods
specified in subdivision one of section seventy-eight shall be increased
by the period from the date of such expiration to the date of the
agreement.

3. Period for assessment against certain transferors.--For purposes of
this section, if any person is deceased or is a corporation which has
terminated its existence, the period of limitation for assessment
against such person or corporation shall be the period that would be in
effect had death or termination of existence not occurred.

4. Evidence.--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 three of section eighty for rule
as to burden of proof.