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COMMISSIONER v. STERN

No. 311.

357 U.S. 39 (1958)

COMMISSIONER OF INTERNAL REVENUE v. STERN, TRANSFEREE.

Supreme Court of United States.

Decided June 9, 1958.

Attorney(s) appearing for the Case

John F. Davis argued the cause for petitioner. With him on the brief were Solicitor General Rankin, Assistant Attorney General Rice and A. F. Prescott.

Walter E. Barton argued the cause for respondent. With him on the brief were William H. Beck and William B. Martin.

Benj. H. Saunders, K. Martin Worthy and Arthur Peter filed a brief for the Life Insurance Association of America, as amicus curiae, urging affirmance.

MR. JUSTICE BRENNAN delivered the opinion of the Court.

Respondent petitioned the Tax Court for redetermination of the liability assessed against her for her deceased husband's unpaid income tax deficiencies. The Tax Court held that, as beneficiary of proceeds of her husband's life insurance exceeding the amount of the deficiencies, the respondent was liable for the full amount of the deficiencies. The Court of Appeals reversed, 242 F.2d 322

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