(IRS could collect estate tax via estate tax lien more than 12 years after taxes assessed; decedent died in 2000 owning assets via revocable trust of approximately $4.57 million and IRA worth $3.85 million; estate tax determined to be approximately $2.47 million; four years of extensions granted via I.R.C. Sec. 616 due to market value decline of publicly traded securities; $200,000 of estate tax paid and insufficient assets in trust to pay balance; IRS sought payment of tax from transferee of IRA under I.R.C. Sec. 6324 estate tax lien; IRS not bound by four year assessment period of I.R.C. Secs. 6501 and 6901(c) and could proceed under I.R.C. Sec. 6324 (10-year provision); 10-year provision extended by four year extension period that had previously been granted to estate, and IRA transferee liability was derivative of estate's liability; immaterial that transferee may have not known of unpaid estate tax; amounts withdrawn from IRA to pay estate tax liability also subject to income tax in transferee's hands; while income tax deduction for estate taxes attributable to IRA available under I.R.C. Sec. 691(c), deduction could be limited due to failure to match tax year of deduction and income).