§ 693. 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, 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
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
six hundred 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 six hundred eighty-seven on the amount of the credit or
refund, the periods specified in subsection (a) of section six hundred
eighty-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 subsection (e) of
section six hundred ninety-seven 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 six
hundred eighty-nine for rule as to burden of proof.

(e) Notwithstanding the provisions of paragraph one of subsection (e)
of section six hundred ninety-seven of this part, the commissioner may
furnish information relating to real property transfers obtained or
derived from returns filed pursuant to this article in relation to the
real estate transfer tax, to the extent that such information is also
required to be reported to the commissioner by section three hundred
thirty-three of the real property law and section five hundred
seventy-four of the real property tax law and the rules adopted
thereunder, provided such information was collected through a combined
process established pursuant to an agreement entered into with the
commissioner pursuant to paragraph viii of subdivision one-e of section
three hundred thirty-three of the real property law. The commissioner
may redisclose such information to the extent authorized by section five
hundred seventy-four of the real property tax law.