Where a person is liable for any tax:
(1) on a lifetime disposition1, otherwise than as transferor or as personal representative2 of the transferor3; or
(2) in respect of a chargeable transfer under the settled property provisions4, otherwise than as trustee of the settlement5,
he is liable only if the tax remains unpaid after it ought to have been paid and, in a case where any part of the value transferred is attributable to the tax on it, is liable to no greater extent than he would have been had the value transferred been reduced by the tax remaining unpaid
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