Section 1.164-6 addresses apportionment between sellers and purchasers and is inapposite for the purposes of this thread.
You misstated Section 1.164-1(a), which reads as follows:
§ 1.164-1 Deduction for taxes.
(a) In general. Only the following taxes shall be allowed as a deduction under this section for the taxable year within which paid or accrued, according to the method of accounting used in computing taxable income:........
There is no requirement that real estate tax must be "imposed" upon the person (who is an owner of the real estate) before the tax paid is deductible. In fact, you should take note that real estate taxes are never imposed upon a person or owner; such taxes are assessed and become a lien on the real estate itself, not any particular individual.
The yield out of all of the foregoing is that anyone with any type of an ownership interest in the property can deduct any real estate taxes assessed in the tax year in which that person pays the real estate tax.
