OPINION AND ORDER The United States brings this action to recover unpaid estate tax liabilities of the Estate of Ana Beatriz Marin (the “Estate”) against defendants (i) Carla L. Marin, individually and as co-executor and beneficiary of the Estate; (ii) Philip D. Marin, individually and as co-executor and beneficiary of the Estate; (iii) Carl F. Marin, individually and as beneficiary of the Estate; (iv) the Estate itself; (v) Putnam County National Bank of Carmel; (vi) Dykeman Scrap Iron Inc.; and (vii) the Town of Southeast. Now pending is the Estate, Carla Marin, and Carl Marin’s (collectively, the “moving defendants”) motion for partial dismissal of the amended complaint pursuant to Rules 12(b)(1), 12(b)(3), and 12(b)(6). (Doc. #73).1 For the following reasons, the motion is DENIED. The Court has subject matter jurisdiction pursuant to 28 U.S.C. §§1331 and 1367. BACKGROUND For the purpose of ruling on the motion to dismiss, the Court accepts as true all well-pleaded allegations in the amended complaint and draws all reasonable inferences in the government’s favor, as summarized below. I. The Estate Ana Beatriz Marin died in November 2007, leaving behind an estate worth $7,438,485, comprising (i) twenty-nine parcels of real property with an estimated fair market value of $6,298,500, (ii) cash, notes, and mortgages worth $1,134,985, and (iii) miscellaneous personal property worth $5,000.2 Ana Marin’s handwritten will named two of her children, Carla and Philip Marin, as co-executors of the Estate. II. The Estate Taxes In February 2008, while the authenticity of Ana Marin’s holographic will was being disputed, the Surrogate’s Court of Putnam County appointed non-party William Carlin as temporary administrator of the Estate. In August 2008, Carlin filed a tax return on behalf of the Estate. In October 2008, the Internal Revenue Service (“IRS”) assessed estate taxes of $1,869,340 against the Estate. In conjunction with the 2008 tax return, and pursuant to 26 U.S.C. §6166, Carlin elected to defer payment of estate tax principal. Under this election, the Estate agreed to make interest-only payments for five years, and thereafter pay the remaining tax principal and interest in up to ten annual installments. The election further required the Estate to provide the IRS either a bond or a consent to a special lien, to ensure the IRS’s interest in the Estate’s tax obligations was protected by collateral. In October 2009, the Surrogate’s Court issued letters testamentary to Carla and Philip Marin, appointing them co-executors of the Estate. Following an audit, in August 2010, the IRS assessed an additional $245,060 estate tax obligation, bringing the Estate’s total estate tax liability to $2,114,400. Pursuant to the installment election, the Estate made interest-only payments from 2008 through 2012. However, the Estate defaulted by failing to make any additional payments and failing to provide the IRS a bond or special lien consent as collateral for the payment deferral. Indeed, the Estate has not made any estate tax payment since its last interest-only payment in 2012. Beginning in October 2010, the IRS sent numerous letters to the Estate respecting its failures to make annual payments and provide a bond or consent lien to secure the IRS’s interest in the Estate’s tax obligation. In July 2012, the IRS notified the Estate it would process the Estate’s default if the Estate continued to neglect its responsibility to provide a bond or consent lien. The Estate failed to provide the necessary documentation. Accordingly, in January 2013, the IRS sent a formal notice to the Estate of its intent to terminate the installment payment election, and demand immediate and full payment of the Estate’s tax liability. In January 2014, Carla Marin notified the IRS that the Estate was unable to make an installment payment, and that the Estate’s property did not appear to be worth the amount owed on the Estate’s tax return. In April 2014, the Surrogate’s Court removed Philip Marin as co-executor of the Estate. Carla Marin then became the sole executor. In July 2014, the IRS formally terminated the Estate’s installment payment election, and thereafter filed notices of federal tax liens in Putnam and Dutchess Counties in New York, and Fairfield County in Connecticut. On February 4, 2015, the IRS notified the Estate of its intent to levy to collect $2,504,778.31 in estate taxes, penalties, and interest, which were then due and owing. In March 2015, Carla Marin informed the IRS that the Estate’s financial condition was “very poor” and the “Estate does not have the assets to fu[ly] pay” its tax liability. (Doc. #70 (“Am. Compl.”) 52) (alteration in original). Further, Carla Marin was “concern[ed]” the total value of Estate assets was insufficient to satisfy such liability. (Id.) (alteration in original). In September 2016, Carla Marin again informed the IRS that the Estate was unable to fully pay its tax liabilities. The Estate’s federal tax liability, including penalties and interest, now exceeds $2.9 million. III. Failure to Report Income According to interim accountings made to the Surrogate’s Court in 2014 and 2017, Carla Marin reported the Estate had earned over $2 million in rental and other income since October 2009. Yet, the Estate has not filed an income tax return since 2010. Indeed, according to Carla Marin’s April 2014 interim accounting, the Estate received roughly $1.23 million in rental and mortgage income from October 2010 through January 2014. And according to Carla Marin’s January 2017 interim accounting, the Estate received an additional $818,000 in income between February 2014 and December 2016. The government alleges the Estate has continued to collect income from Estate assets, including payments on certain mortgage notes it currently holds, and has failed to report this income to the IRS. IV. Receipt and Use of Estate Property According to the government, upon Ana Marin’s death, Carla Marin received from the Estate more than $642,000, Carl Marin more than $20,000, and Philip Marin more than $8,000, in cash, which was deposited and held in certain “in trust for,” or “ITF,” accounts. In addition, both before and after receiving notice that federal estate taxes were due and owing, the Estate paid debts to certain creditors, even though such creditors allegedly did not have priority over the IRS’s interest in the Estate’s outstanding tax debt. For example, from October 2010 through January 2014, the Estate paid approximately $1.46 million for what is described as administrative expenses, including debts for advertising costs, bank fees, property maintenance costs and taxes, and insurance. And from February 2014 through December 2016, the Estate paid roughly $787,000 for similar administrative expenses. The government alleges the Estate continues to use Estate funds to pay administrative expenses to creditors for debts lacking priority over the IRS’s federal tax liens. In addition, the government alleges that during her tenure as an executor of the Estate, Carla Marin resided in, and used for her own personal benefit, certain Estate properties, and also used Estate funds for her own personal benefit. For example, Carla Marin’s last known address is 65 Hill Road, Carmel, New York, an Estate asset. She lists her law firm’s address as 1762 Route 6, Carmel, New York, also an Estate asset. According to the government, Carla Marin continues to use these properties for her own benefit. DISCUSSION I. Legal Standards A. Rule 12(b)(1) “[F]ederal courts are courts of limited jurisdiction and lack the power to disregard such limits as have been imposed by the Constitution or Congress.” Durant, Nichols, Houston, Hodgson & Cortese-Costa, P.C. v. Dupont, 565 F.3d 56, 62 (2d Cir. 2009).3 A cause of action “is properly dismissed for lack of subject matter jurisdiction under Rule 12(b)(1) when the district court lacks the statutory or constitutional power to adjudicate it.” Nike, Inc. v. Already, LLC, 663 F.3d 89, 94 (2d Cir. 2011). The party invoking the Court’s jurisdiction bears the burden to establish that jurisdiction exists. Lujan v. Defs. of Wildlife, 504 U.S. 555, 561 (1992). When deciding whether subject matter jurisdiction exists at the pleading stage, the Court “must accept as true all material facts alleged in the complaint and draw all reasonable inferences in the plaintiff’s favor.” Conyers v. Rossides, 558 F.3d 137, 143 (2d Cir. 2009). “However, argumentative inferences favorable to the party asserting jurisdiction should not be drawn.” Atl. Mut. Ins. Co. v. Balfour Maclaine Int’l Ltd., 968 F.2d 196, 198 (2d Cir. 1992). B. Rule 12(b)(3) In deciding a Rule 12(b)(3) motion to dismiss for improper venue, the Court must take all allegations in the complaint as true, unless challenged by defendants. U.S. E.P.A. ex rel. McKeown v. Port Auth. of N.Y. & N.J., 162 F. Supp. 2d 173, 183 (S.D.N.Y. 2001), aff’d sub nom. McKeown v. Del. Bridge Auth., 23 F. App’x 81 (2d Cir. 2001) (summary order).4 “When an allegation is so challenged a court may examine facts outside the complaint to determine whether venue is proper. The court must draw all reasonable inferences and resolve all factual conflicts in favor of the plaintiff.” Id. It is the plaintiff’s burden to show venue is proper in the forum district. Saferstein v. Paul, Mardinly, Durham, James, Flandreau & Rodger, P.C., 927 F. Supp. 731, 735 (S.D.N.Y. 1996). C. Rule 12(b)(6) In deciding a Rule 12(b)(6) motion, the Court evaluates the sufficiency of the operative complaint under the “two-pronged approach” articulated by the Supreme Court in Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). First, a plaintiff’s legal conclusions and “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements,” are not entitled to the assumption of truth and are thus not sufficient to withstand a motion to dismiss. Id. at 678; Hayden v. Paterson, 594 F.3d 150, 161 (2d Cir. 2010). Second, “[w]hen there are well-pleaded factual allegations, a court should assume their veracity and then determine whether they plausibly give rise to an entitlement to relief.” Ashcroft v. Iqbal, 556 U.S. at 679. To survive a Rule 12(b)(6) motion, the complaint’s allegations must meet a standard of “plausibility.” Ashcroft v. Iqbal, 556 U.S. at 678; Bell Atl. Corp. v. Twombly, 550 U.S. 544, 564 (2007). A claim is facially plausible “when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. at 678. “The plausibility standard is not akin to a ‘probability requirement,’ but it asks for more than a sheer possibility that a defendant has acted unlawfully.” Id. (quoting Bell Atl. Corp. v. Twombly, 550 U.S. at 556). II. Section 3713 Personal Liability Claim The moving defendants argue the government has failed to state a claim under 31 U.S.C. §3713 against Carla Marin. Specifically, they contend the government has not plausibly alleged the Estate is insolvent or that Carla Marin made payments to creditors in contravention of the IRS’s priority debt position. Moreover, they argue the government’s claim is barred by the doctrine of collateral estoppel. The Court disagrees. A. Insolvency and Priority Section 3713, commonly referred to as the federal priority statute, provides: “A claim of the United States Government shall be paid first when — the estate of a deceased debtor, in the custody of the executor or administrator, is not enough to pay all debts of the debtor.” 31 U.S.C. §3713(a)(1)(B). “A representative of…an estate…paying any part of a debt of the…estate before paying a claim of the Government is liable to the extent of the payment for unpaid claims of the Government.” Id. §3713(b). “Accordingly, by the statute’s express terms, liability is imposed on a representative of a debtor, including an executor of an estate, who pays a debt of the estate to another in derogation of the priority of debts owed to the United States, thereby rendering the estate insolvent.” United States v. Coppola, 85 F.3d 1015, 1020 (2d Cir. 1996). For liability to attach, the estate’s representative or executor must have knowledge of, or sufficient reason to know of, the debt owed by the estate to the United States. Id. “There is no question that taxes owed to the United States fall within the scope of…the statute’s broad terms.” Id. The amended complaint sufficiently alleges a Section 3713 claim against Carla Marin. As co-executor and, eventually, sole executor of the Estate, Carla Marin knew of the Estate’s federal tax obligations. Indeed, she corresponded with the IRS on multiple occasions respecting same. She thus had knowledge of the Estate’s debt owed to the United States. See United States v. Coppola, 85 F.3d at 1020. Furthermore, the government plausibly alleges the Estate is insolvent. Indeed, Carla Marin allegedly informed the IRS the Estate’s property did not appear to be worth the Estate’s outstanding tax liability, and that the Estate’s financial condition was “very poor.” (Am. Compl. 52). She also noted the “Estate does not have the assets to fu[ly] pay” the estate taxes. (Id.) (alteration in original). The government also plausibly alleges Carla Marin, as executor, paid Estate debts to other creditors, over which the government held a priority interest. Put another way, the allegations of the amended complaint plausibly suggest Carla Marin remitted Estate funds to pay certain “administrative expenses” — including fuel and car payments — while the government’s outstanding tax liens, which had priority over such administrative expenses, remained unpaid. (Am. Compl.
