Transferee Liability - A person may be held LIABLE for another taxpayer's delinquent taxes if:

1. The transferee received assets of the transferor-taxpayer; and

2. The transferor was INSOLVENT at the time or was rendered insolvent by that transfer or related series of transfers.
However the insolvency requirement does not apply to GIFT taxes. The transferee is only liable to the extent of the value of the property received from the transferor. Thus, transferee liability merely provides a means for IRS to recover any assets the transferor-taxpayer attempts to transfer to avoid paying taxes.