TUTTLE, Circuit Judge.
The sole question here is whether appellee, the named beneficiary and the recipient of the proceeds of an insurance policy on the life of her deceased husband, is liable as a transferee for the husband's unpaid income taxes in an amount exceeding the cash surrender value of the policy, where the husband died insolvent.
The facts in the record are undisputed. Appellee is the widow and administratrix of Layton E. Truax, who died insolvent...
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