With the introduction of the institution of inheritance management into the Polish legal system, it became necessary for the legislator to regulate a number of private and public law regulations related to the activity of the manager after the death of the entrepreneur. The special regulation of the tax subjectivity of an inheritance business and the way of carrying out its management after the entrepreneur's death means the appearance of new, previously unknown entities in tax proceedings (i.e. inheritance business, inheritance manager, inheritance business owner, etc.). Consequently, it is necessary to determine their legal status on the basis of the provisions regulating these procedures. The problem of subjectivity of the inheritance manager is also present in the issuance of a tax decision, since, according to the substantive law, the subject of the decision was, until now, the entrepreneur. The aim of this paper is to present the substantive, legal and procedural status of an inheritance manager and, consequently, to answer whether a manager will be the subject of a tax decision.