§ 1449-i. Liability for tax. 1. The real estate transfer tax shall be
paid by the grantor. If the grantor has failed to pay the tax imposed
pursuant to this article or if the grantor is exempt from such tax, the
grantee shall have the duty to pay the tax. Where the grantee has the
duty to pay the tax because the grantor has failed to pay, such tax
shall be the joint and several liability of the grantor and the grantee.

2. For the purpose of the proper administration of this article and to
prevent evasion of the tax hereby authorized, it shall be presumed that
all conveyances are taxable. Where the consideration includes property
other than money, it shall be presumed that the consideration is the
fair market value of the real property or interest therein. These
presumptions shall prevail until the contrary is proven, and the burden
of proving the contrary shall be on the person liable for payment of the
tax.