§ 73. 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 to the city under this local law, 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 administrator 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 administrator 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 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 sixty-seven. 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 sixty-seven on the amount of the credit or refund, the periods
specified in subdivision (a) of section sixty-seven 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 section
seventy-eight, the administrator 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 sixty-nine for
rule as to burden of proof.