Section 11-684. Transferees

1. 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
  subchapter  or under the named subchapters, 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,
  in  case  of  successive  transfers,  donee,  heir,  legatee,   devisee,
  distributee,   and   successor   by   merger,   consolidation  or  other
  reorganization.
    2. Exceptions.
    (a) 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 preceding 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.
    (b)  If,  before  the expiration of the time prescribed in subdivision
  one 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 or  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  two  of
  section  11-678  of  this subchapter. 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
  two of section 11-678 of this subchapter on the amount of the credit  or
  refund,  the  period  specified  in subdivision one of section 11-678 of
  this subchapter shall be increased by the period from the date  of  such
  expiration to the date of the agreement.
    3.  Period for assessment against certain transferors. For purposes of
  this section, if any person is deceased or is a  corporation  which  has
  terminated  its  existence,  the  period  of  limitation  for assessment
  against such person or corporation shall be the  period  that  would  be
  effect had death or termination of existence not occurred.
    4.  Evidence.  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 five of section 11-680
  of this subchapter for rule as to burden of proof.