RECOMMENDED!!Two years ago, Herbert, a widower, made a gift of marketable securities

  

Estate Tax LiableTwo years ago, Herbert, a widower, made a gift of marketable
securities to his 35-year-old daughter, Sabrina, on which he paid a Federal
gift tax of $3 million. Herbert dies in the current year and his estate is
greatly reduced in value due to his having given away most of his assets over
his lifetime.Herbert’s executor files an estate tax return showing a
gross estate of slightly more than $3 million. The estate tax of $1 million
that is attributable to the $3 million is not paid because the estate has no
liquid assets.
The IRS assesses the $1 million estate tax against Sabrina
under the rules relating to transferee liability. Is Sabrina liable for the
estate tax?

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