Does 26 U.S.C. § 6324(a)(2) allow the Government to impose personal liability on transferees, trustees or beneficiaries who receive property from the decedent's estate only at the time of decedent's death, or is the United States Court of Appeals for the Ninth Circuit correct that 26 U.S.C. § 6324(a)(2) allows the imposition of personal liability for estate taxes on persons who receive estate property at any time after the decedent's death and in amounts which could potentially exceed the current value of the property received?

QUESTION PRESENTED FOR REVIEW The Internal Revenue Service has significant powers to collect estate taxes under the Internal Revenue Code. The ordinary method is through an automatic ten-year tax lien which attaches to the decedent’s estate. The IRS can also require the estate to post a surety bond or can require a special lien. Finally, the Internal Revenue Code allows the Government the additional, extraordinary power to pursue certain enumerated recipients of estate property personally for unpaid estate taxes under certain circumstances. The question presented here is: Does 26 U.S.C. § 6324(a)(2) allow the Government to impose personal liability on transferees, trustees or beneficiaries who receive property from the decedent’s estate only at the time of decedent’s death, as the Tax Court and every federal court which has considered the issue has held, or is the United States Court of Appeals for the Ninth Circuit correct that 26 U.S.C. § 6324(a)(2) allows the imposition of personal liability for estate taxes on persons who receive estate property at any time after the decedent’s death and in amounts which could potentially exceed the current value of the property received?