> Someone close to me owns very large amounts of property,
>> roughly valued at more than $2 million. Most of it is owned...
> Transferee liability. See Code section 6324(a)(2).
>
> If the estate tax is not paid when due, then any of the
> following who receives, or who has on the date of the
> decedent's death, property included in the decedent's gross
> estate under Code Sec. 2034 through Code Sec. 2042 (this
> includes joint property, which is subject to estate tax
> under section 2040), is personally liable for the unpaid
> estate tax, to the extent of the value on the date of the
> decedent's death of the property received or possessed:
>
> ... spouse
> ... transferee
> ... trustee, other than the trustee of a qualified employee
> trust
> ... surviving tenant
> ... person in possession of property by reason of the
> exercise, nonexercise, or release of a power of
> appointment
> ... beneficiary
>
> If everyone is cooperative, each of the people that receives
> a share of the estate will pony up their fair share of the
> estate tax. If not, then the IRS can go after all of them,
> or any one of them individually. If they go after the
> beneficiaries individually, then it's up the the
> beneficiaries to go after the other beneficiaries for
> reimbursement.
Interesting - would the IRS go after the beneficiaries proportionately, ie. if the spouse receives 1/4 of the estate, one child 1/4 and another child 1/2 will the IRS go after them for that part of the taxes or go after each of them for the entire tax bill? Many thanks to everyone who has responded, this is what I feared but wasn't sure of - now maybe I can convince him to get an ILIT going...
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