GARRECHT, Circuit Judge.
The question here is whether petitioner is liable as a transferee under Section 311 of the Internal Revenue Code, Title 26, U.S.C.A. Int.Rev.Code, § 311, for income taxes due from the decedent whose estate is insolvent by reason of petitioner's receipt of insurance proceeds under a California statute authorizing the probate court to set over to the surviving spouse all or any part of the property of the decedent "exempt from execution...
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