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ARLINGTON CORP. v. COMMISSIONER OF INTERNAL REVENUE

No. 13033.

183 F.2d 448 (1950)

ARLINGTON CORP. v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fifth Circuit.

July 17, 1950.

Attorney(s) appearing for the Case

Edward E. Dorsey, Hal Lindsay and Travers Hill, all of Atlanta, Ga., for petitioner.

S. Dee Hanson, Ellis N. Slack, Helen Goodner, Special Assts. to Atty. Gen., Theron Lamar Caudle, Asst. Atty. Gen., and Charles Oliphant, Chief Counsel, Bureau of Int. Revenue, John M. Morawski, Special Attorney, all of Washington, D. C., for respondent.

Before HUTCHESON, Chief Judge, and McCORD and RUSSELL, Circuit Judges.

McCORD, Circuit Judge.

This appeal is from an order of the Tax Court dismissing a petition of petitioner, The Arlington Corporation, for redetermination of its liability as an alleged fraudulent transferee of the assets of Walton Hill Irwin and Mrs. Annie Lee Irwin. The Commissioner has entered a jeopardy assessment against petitioner as transferee of the above named individuals in the aggregate sum of $363,702.56, for individual income and victory taxes and 50% fraud...

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