Rowen v. Commissioner
United States Tax Court
1. The transferor was held to have filed fraudulent tax returns, Louis Halle, 7 T. C. 245. This decision became final after certiorari was denied by the Supreme Court on February 6, 1950. Held, notice of transferee liability mailed to petitioner on September 14, 1950, was timely, section 311 (b) and (d) of the Code. 2. Louis Halle died insolvent in 1949 owing income taxes in substantial amounts. Proceeds from decedent's life insurance were received by petitioners.
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1. The transferor was held to have filed fraudulent tax returns, Louis Halle, 7 T. C. 245. This decision became final after certiorari was denied by the Supreme Court on February 6, 1950. Held, notice of transferee liability mailed to petitioner on September 14, 1950, was timely, section 311 (b) and (d) of the Code. 2. Louis Halle died insolvent in 1949 owing income taxes in substantial amounts. Proceeds from decedent's life insurance were received by petitioners. Held, petitioners are liable as transferees to the extent of life insurance proceeds received by them. Christine D. Muller, 10 T.…
1Opinion of the Court
OPINION.
Black, Judge:
Three issues are presented in these proceedings. We shall consider each issue in the order set forth in our preliminary statement. The first two issues are questions of law, and the third issue is primarily one of fact.
Issue 1.
As to the first issue, petitioners contend that the statute of limitations bars any assessment of tax against them as transferees. The applicable provision of the Code, section 311, reads as follows:
SEC. 311. TRANSFERRED ASSETS.
*******(b) Period of Limitation. — Tlie period of- limitation for assessment of any such liability of a transferee or…
2Cases cited3 opinions
- Muller v. CommissionerUnited States Tax Court · 1948
- Commissioner of Internal Revenue v. KellerCourt of Appeals for the Seventh Circuit · 1932
- Leary v. CommissionerUnited States Tax Court · 1952
3Cited by29 opinions
- Looper v. CommissionerUnited States Tax Court · 1980
- Kreps v. CommissionerUnited States Tax Court · 1964
- Peurifoy v. CommissionerUnited States Tax Court · 1956
- Ruth Halle Rowen, Ethel F. Halle, and Edward Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
- Bartmer Automatic Self Service Laundry, Inc. v. CommissionerUnited States Tax Court · 1960
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