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SANTOS v. COMMISSIONER OF INTERNAL REVENUE

No. 15866.

260 F.2d 583 (1958)

Irmgard SANTOS, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Ninth Circuit.

August 8, 1958.

Attorney(s) appearing for the Case

Robert Ash, Carl F. Bauersfeld, Washington, D. C., for petitioner.

Charles K. Rice, Asst. Atty. Gen., Harry Marselli, Lee A. Jackson, Robert N. Anderson, James P. Turner, Attorneys, Department of Justice, Washington, D. C., for respondent.

Before STEPHENS, Chief Judge, and DENMAN and FEE, Circuit Judges.

JAMES ALGER FEE, Circuit Judge.

The Commissioner made a jeopardy assessment against Irmgard Santos on October 15, 1952, on the ground that she was transferee of the assets of her husband, Lawrence Santos, on account of income taxes owed by him for previous years. A considerable sum of interest was also assessed on the transferee liability. The amount of the individual income tax overpayment of Irmgard Santos had previously been determined pursuant to stipulation in...

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