DENMAN, Chief Judge.
Irmgard Santos petitions us to review a decision of the Tax Court upholding an assessment by the Commissioner of a deficiency against her of $68,287.90, under Section 311 of the Internal Revenue Code of 1939, 26 U.S.C.A. § 311, for income taxes owed by her husband, Lawrence Santos, for the years 1943-6.
Under Section 311 a transferee of property of a taxpayer may be liable for the taxes of the transferor if the Commissioner sustains...
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