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ROWEN v. COMMISSIONER OF INTERNAL REVENUE

Nos. 22955-22957.

215 F.2d 641 (1954)

Ruth Halle ROWEN, Ethel F. Halle, and Edward Halle, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals, Second Circuit.

Decided September 9, 1954.

Attorney(s) appearing for the Case

Edward Halle, New York City, for petitioners.

H. Brian Holland, Asst. Atty. Gen. (Ellis N. Slack, S. Dee Hanson, Special Assts. to the Atty. Gen., of counsel), for respondent.

Before CHASE, Chief Judge, and HINCKS and HARLAN, Circuit Judges.

HINCKS, Circuit Judge.

This petition for review of a Tax Court decision, 18 T.C. 874, raises the question whether the receipt by named beneficiaries (the petitioners herein) of the proceeds of certain life insurance policies subjected them to liability enforceable against them as transferees under I.R.C. § 311, 26 U.S.C.A. § 311.

The facts of the case are as follows. Louis Halle of New York City, hereinafter referred...

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