Liability to pay tax and related charges transfers to successors or estate when business ceases or interests are reconstituted. Where a person liable for tax, interest or penalty dies, the legal representative or any person continuing the business is liable to pay such amounts, and if the business is discontinued the legal representative is liable out of the estate to the extent of estate capacity; this covers amounts determined before death but unpaid and amounts determined after death. Similar joint and several liability rules apply on partition of a collective taxpayer, dissolution of a firm, and termination of guardianship or trust, subject to insolvency exceptions.
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Provisions expressly mentioned in the judgment/order text.
Liability to pay tax and related charges transfers to successors or estate when business ceases or interests are reconstituted.
Where a person liable for tax, interest or penalty dies, the legal representative or any person continuing the business is liable to pay such amounts, and if the business is discontinued the legal representative is liable out of the estate to the extent of estate capacity; this covers amounts determined before death but unpaid and amounts determined after death. Similar joint and several liability rules apply on partition of a collective taxpayer, dissolution of a firm, and termination of guardianship or trust, subject to insolvency exceptions.
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