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?

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?