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COLE v. C. I. R.

No. 16755.

297 F.2d 174 (1961)

Frances M. COLE, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Eighth Circuit.

December 28, 1961.

Attorney(s) appearing for the Case

James A. Poynor, Joplin, Mo., filed brief for petitioner.

Louis F. Oberdorfer, Asst. Atty. Gen., Department of Justice, Washington, D. C. and Lee A. Jackson, A. F. Prescott, Karl Schmeidler, Attorneys, Department of Justice, Washington, D. C., filed brief for appellee.

Before SANBORN, MATTHES and RIDGE, Circuit Judges.

SANBORN, Circuit Judge.

The Commissioner of Internal Revenue on July 29, 1957, advised Frances M. Cole that the determination of the income tax liability of her husband, Charles N. Cole, of Joplin, Missouri, for the years 1951, 1952 and 1953 disclosed deficiencies and penalties aggregating $46,049.94, and that $12,000 of that amount had been assessed against her as transferee of assets of her husband. Mrs. Cole petitioned...

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