the original taxpayer. See Defs.’ Reply at 2-3. This distinction, however, is of no consequence. The IRC- does not require the United States to assess and sue the original taxpayer prior to assessing a transferee. To the contrary, the IRC allows the United States to assess and sue either a transferee or a “transferee of a transferee” so long as the relevant time limitations are followed. Compare 26 U.S.C. § 6901(a)(1)(A) (discussing the liabilities of a transferee) with 26 U.S.C. § 6901(c)(2) (discussing the liabilities of a transferee of a transferee). In the present case, J. Brickman, a transferee of the original titution of a suit to enforce tax liability extends the life of an assessment lien beyond the six-year period); Hector v. United States, 255 F.2d 84, 85 (5th Cir.1958) (<HOLDING>); Ettelson, 159 F.2d at 196 (holding claim
holding that properly filed application for statecourt discretionary review tolls aedpa limitations period holding that a properly filed motion to reconsider under colo rcrim p 35b tolls the oneyear limitations period holding that limitations provision of section 1821d14 of firrea is applicable to suit on note brought by fdics assignee preempts state fouryear limitations period and extends limitation period to six years holding that the charge was timely when filed within the statute of limitations period even though served after the period holding that suit filed within six years of assessment tolls the limitation period indefinitely