Court Rules Estate Tax Statute of Limitations Applies to Transferee

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The 10-year statute of limitations under tax code Section 6324 applies to the collection from a transferee of unpaid federal estate taxes, and not the four year statute of limitations under tax code Section 6901, the U.S. District Court for the Southern District of Florida ruled July 22 (United States v. Mangiardi, S.D. Fla., No. 9:13-cv-80256, 7/22/13).
District Judge Kenneth A. Marra made the ruling denying a motion to dismiss a collection action by the Internal Revenue Service against a beneficiary of a decedent's trust and individual retirement account for an unpaid federal estate tax liability in excess of $3 million.
The defendant transferee in the action, Maureen G. Mangiardi, was the daughter of the decedent, Dr. Joseph L. Mangiardi, and a co-trustee of his will and trust.