A recent case from the 11th circuit, U.S. v. Henco Holding Corp., is an important case in regard to the tax enforcement of transferee liability. The two biggest takeaways from the case are: one, a reminder that a state statute of limitations is not binding on the IRS, with the Court noting that it has long been held that the federal government does not become subject to a state statute of limitations when it is acting in its governmental capacity and asserting a claim under its rights as the federal government; and two, that a transferee assessment under IRC 6901 is not necessary to proceed against individual shareholder-transferees where the parent company had been properly and timely assessed. “Proving” transferee liability under the applicable state statutes still applies, however.