Applicable provisions
(3) Applicable provisions. The provisions of the Code made applicable by section 6901(a) to the liability of a transferee or fiduciary referred to in subparagraphs (1) and (2) of this paragraph (a), include the provisions relating to: (i) Delinquency in payment after notice and demand and the amount of interest attaching because of such delinquency; (ii) The authorization of distraint and proceedings in court for collection; (iii) The prohibition of claims and suits for refund; and (iv) In any instance in which the liability of a transferee or fiduciary is one referred to in subparagraph (1) of this paragraph (a), the filing of a petition with the Tax Court of the United States and the filing of a petition for review of the Tax Court's decision.