TRANSFEREE LIABILITY FOR ESTATE TAXES CAN BECOME A NEVER ENDING STORYTRANSFEREE LIABILITY FOR ESTATE TAXES CAN BECOME A NEVER ENDING STORY
In a recent federal district court case, the beneficiaries of a decedent's revocable trust and individual retirement account were held to be personally liable for more than $3 million in unpaid estate taxes, even though no assessment or collection action against the beneficiaries had been commenced until more than ten years after the decedent's death. According to the recent US District Court decision in US v. Mangiardi (Southern District of Florida, July 19, 2013), a beneficiary's exposure for transferee liability for federal estate taxes can last for more than a decade after the decedent's death. In fact, the Court concluded that the limitations period for collecting the tax from a beneficiary is no different from that for collecting...
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