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PATTERSON v. SIMS

No. 18121.

281 F.2d 577 (1960)

George D. PATTERSON, District Director of Internal Revenue, for District of Alabama, Appellant and Cross-Appellee, v. L. A. SIMS, Appellee and Cross-Appellant. L. A. SIMS, Appellee and Cross-Appellant, v. George D. PATTERSON, District Director of Internal Revenue, for District of Alabama, Appellant and Cross-Appellee.

United States Court of Appeals Fifth Circuit.

August 5, 1960.

Attorney(s) appearing for the Case

Joseph Kovner, Lee A. Jackson, Attys., Dept. of Justice, Washington, D. C., Charles K. Rice, Asst. Atty. Gen., W. L. Longshore, U. S. Atty., Birmingham, Ala., Harry Baum, Atty., Dept. of Justice, Washington, D. C., M. L. Tanner, Asst. U. S. Atty., Birmingham, Ala., for appellant.

J. Foy Guin, Jr., Russellville, Ala., Guin, Guin & Cleere, Russellville, Ala., of counsel, for appellee and cross-appellant.

Before RIVES, Chief Judge, and JONES and WISDOM, Circuit Judges.

RIVES, Chief Judge.

This appeal and cross-appeal concern the extent of the liability for interest of a transferee of property1 of a delinquent income taxpayer.

The facts were stipulated and may be briefly summarized. On March 13, 1950, delinquent income taxes for the years 1946 and 1947 were assessed against Jennie M. Brown, totalling for both years $39,792.48, taxes, plus $5,406.28, interest, and $19,752.25, penalty, or an aggregate...

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