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CCH (cch.taxgroup.com) reports:

A law firm was a successor to its predecessor law firm; therefore, it was liable for the predecessor's unpaid employment taxes and other tax liabilities and could not maintain a wrongful levy action against the government with respect to those liabilities. The corporation had successor liability because it fell within the "continuity" exception to the general rule of state (Pennsylvania) law, which holds that a successor is not liable for the debts of its predecessor firms.
The government established a continuity of ownership, operations and corporate management between the two law firms. The differences between the size and specialization of the two law firms did not cleanse the successor of liability, and the transfer of assets for less than adequate consideration was deemed an artificial transfer of ownership for the purpose of evading liabilities.
Also weighing in favor of applying the continuity exception was the fact that the predecessor law firm ceased to exist, while the successor firm survived, indicating a de facto merger. Finally, the successor firm assumed obligations necessary for uninterrupted continuation of normal business operations, such as the predecessor law firm's lease, clients, personnel, office supplies and malpractice insurance contract, and it continued the firm's relationship with outside service providers such as the predecessor's accountant and payroll service.
Hwang Law Firm, LLC, DC Pa., 2008-2 USTC ¶50,468
Other References:
Code Sec. 7426
CCH Reference - 2008FED ¶41,713.44
Tax Research Consultant
CCH Reference - TRC IRS: 51,156.05