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TYSON v. COMMISSIONER OF INTERNAL REVENUE

No. 11997.

212 F.2d 16 (1954)

TYSON v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Sixth Circuit.

April 28, 1954.

Attorney(s) appearing for the Case

John B. Poole, Detroit, Mich., for petitioner.

Fred Youngman, Washington, D. C. (H. Brian Holland, Ellis N. Slack, A. F. Prescott, George F. Lynch, Washington, D. C., on the brief), for respondent.

Before ALLEN and McALLISTER, Circuit Judges, and GOURLEY, District Judge.

PER CURIAM.

The appeal relates to the interpretation of section 311(a) (1), (f) of the Internal Revenue Code and poses the question:

Does the Commissioner of Internal Revenue have authority to hold a wife-beneficiary of a life insurance policy liable for unpaid income taxes of a deceased spouse as transferee of her husband's assets?

The Tax Court answered in the affirmative and sustained a deficiency assessment by the Commissioner.

After consideration...

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