The entirety of 164.1(a) reads:
In addition, there shall be allowed as a deduction under this section State and local and foreign taxes not described in subparagraphs (1) through (5) of this paragraph which are paid or accrued within the taxable year in carrying on a trade or business or an activity described in section 212 (relating to expenses for production of income). For example, dealers or investors in securities and dealers or investors in real estate may deduct State stock transfer and real estate transfer taxes, respectively, under section 164, to the extent they are expenses incurred in carrying on a trade or business or an activity for the production of income. In general, taxes are deductible only by the person upon whom they are imposed. However, see § 1.164–5 in the case of certain taxes paid by the consumer.
The taxes were never imposed on the offspring. If the child bought the property from the father, the child could not deduct the back taxes. If a stranger bought the property from the father, the stranger could not deduct the back taxes. It is unclear why inheriting the property would be different in how the taxes are apportioned.
The seller may want to consult their own local expert.
