Temporal divergence between tax assessment and remission under Section 28a ErbStG - lawful practice of the tax authorities?

In this article, Dr. Martin Liebernickel and Dr. Fabian Schmitt deal with the problem of a temporal divergence between tax assessment and remission pursuant to Section 28a Inheritance Tax Act, which is practiced by parts of the tax authorities. They explain the tax consequences of such a practice and show which possible solutions exist de lege lata and de lege ferenda in order to dispel fiscal concerns in the case of a temporal concurrence of tax assessment and remission.