Section 11-533. 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 commissioner of finance under this chapter,
  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  commissioner  of  finance in any court against the
  original taxpayer or the  last  preceeding  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 subdivision
  (a) of this section or  the  immediately  preceding  paragraph  of  this
  subdivision  for  the  assessment  of the liability, the commissioner of
  finance 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 subdivision (b) of section 11-527 of this chapter. 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  subdivision (b) of section 11-527 of this chapter on
  the amount of the credit or refund, the periods specified in subdivision
  (a) of section 11-527 of this chapter shall be increased by  the  period
  from the date of such expiration to the date of agreement.
    (c)  Deceased  transferor.  If  any  person is deceased, the period of
  limitation for assessment against such person shall be the  period  that
  would be in effect if such person had lived.
    (d)  Evidence.  Notwithstanding  the  provisions of subdivision (e) of
  section 11-537 of this chapter the commissioner of finance shall use his
  or her 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  subdivision  (e)  of
  section 11-529 of this chapter for rules as to burden of proof.