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NOELL v. COMMISSIONER

Docket No. 42434.

24 T.C. 329 (1955)

LOUISE NOELL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 6, 1955.

Attorney(s) appearing for the Case

Gilbert Weiss, Esq., for the petitioner.

Thomas N. Chambers, Esq., for the respondent.

SUPPLEMENTAL OPINION.

ARUNDELL, Judge:

In an earlier opinion reported at 22 T.C. 1035, we determined that the petitioner herein, Louise Noell, was liable as the transferee of her husband, Charles P. Noell, for his outstanding income tax liability for 1949. The findings of fact reported there are incorporated herein by reference.

In finding petitioner liable as a transferee, however, we decided, on the basis...

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