101. Liability of partnership to inheritance tax.

Inheritance tax1, being chargeable primarily on death, renders the majority of inter vivos transfers of value potentially exempt, so that such transfers become chargeable only if the donor dies within the next seven years following the transfer2. Thus, if, upon the commencement or during the continuation of the firm or upon the death or retirement of a partner, a gratuitous transfer or assignment of one or more partner's shares is effected