Problem: Two years ago, Herbert, a widower, made a gift of marketable securities to his 35-year-old daughter, Sabrina, on which he paid a Federal gift tax of $3 million. Herbert dies in the current year and his estate is greatly reduced in value due to his having given away most of his assets over his lifetime. Herbert's executor files an estate tax return showing a gross estate of slightly more than $3 million. The estate tax of $1 million that is attributable to the $3 million is not paid because the estate has no liquid assets. The IRS assesses the $1 million estate tax against Sabrina under the rules relating to transferee liability. Is Sabrina liable for the estate tax?