§ 1093. 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 tax commission under this article or
under article nine, nine-a, nine-b or nine-c, 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.

(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
tax commission 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 subsection (a)
or the immediately preceding paragraph of this subsection for the
assessment of the liability, the tax commission 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 subsection (b) of section
one thousand eighty-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 subsection (b)
of section one thousand eighty-seven on the amount of the credit or
refund, the periods specified in subsection (a) of section one thousand
eighty-seven shall be increased by the period from the date of such
expiration to the date of the agreement.

(c) 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.

(d) Evidence.---The tax commission shall use its 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 subsection (e) of section one thousand
eighty-nine for rule as to burden of proof.