This proceeding involves the determination of the petitioner's liability, as transferee, for deficiencies in income tax assessed against her deceased husband. The amounts are $3,315.91 for the year 1946 and $100.02 for the year 1947. Two questions are involved: (1) Whether the statute of limitations has barred assessment against petitioner; and (2) whether the insurance proceeds which petitioner received as beneficiary in policies on her husband's life are transferred assets...
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