Commissioner v. Stern

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, holding that the respondent was not liable even to the extent of the amount of the cash surrender values of the policies, which was less than the amount of the deficiencies. We granted certiorari. 355 U. S.…