RIVES, Circuit Judge.
The question to be decided is whether the appellee, widow of Francis A. Knauer, who was beneficiary of her husband's life insurance and also administratrix of his estate is liable for her deceased husband's unpaid federal income taxes when, as administratrix, she had exhausted the assets of the estate, other than life insurance, in payment of federal estate taxes prior to knowledge of liability for income tax. Two grounds are urged upon which...
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