Liability for payment of the tax continues until the tax is paid to the extent of assets which, at the time of decedent's death, or thereafter, became subject to the control of the personal representative. Distribution of the assets does not extinguish liability.
Cal. Code Regs. Tit. 2, § 1138.64
Note: Authority cited: Section 14103, Revenue and Taxation Code. Reference: Section 13530, Revenue and Taxation Code.