Pallister v. United States

PALMIERI, District Judge.

The plaintiff, as administratrix of the estate of a deceased transferee, seeks a refund for interest paid on the decedent’s transferee tax liability. The transferee’s liability was assessed and paid pursuant to Int.Rev.Code of 1954 § 6901, 26 U.S. C.A. § 6901, which provides a summary method of collecting the amount of “the liability, at law or in equity, of a transferee of property * * * of a taxpayer * * See Phillips v. Commissioner, 1931, 283 U.S. 589, 594, 51 S.Ct. 608, 75 L.Ed. 1289; cf. Rowen v. Commissioner, 2 Cir., 1954, 215 F.2d 641.

There are no disputed…