TRANSFEREE 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,

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