Statutes of Limitation
Statute of Limitation from other than Taxpayers - Transferee Liability
  1. IRS has one year after expiration of statute of limitations to administratively assess transferee liability. IRC § 6901(c).
  2. Alternatively, IRS can commence an action to impose transferee liability under state of federal fraudulent conveyance acts. IRS position is that there is no statute of limitations with respect to such actions.
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