Section 73. 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 to the city  under  this  local  law,  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  administrator  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.
    (2) If, before the expiration of the time  prescribed  in  subdivision
  (a)  or  the immediately preceding paragraph of this subdivision for the
  assessment of the liability, the administrator 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  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 sixty-seven. 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  sixty-seven  on the amount of the credit or refund, the periods
  specified in subdivision (a) of section sixty-seven shall  be  increased
  by  the  period  from  the  date  of  such expiration to the date of the
  agreement.
    (c) Deceased transferor.-- If any person is deceased,  the  period  of
  limitation  for assessment against him shall be the period that would be
  in effect if he had lived.
    (d)   Evidence.--Notwithstanding    the    provisions    of    section
  seventy-eight,  the administrator shall use his 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 sixty-nine for
  rule as to burden of proof.