Legal Opinion

Hampton v. Commissioner

United States Tax Court

Decided June 25, 1958No. Docket No. 59759Published

Respondent determined that petitioner was liable as a transferee for the admitted income tax liability of her deceased husband to the extent of amounts received as beneficiary of policies of insurance on her husband's life. Both petitioner and her deceased husband were residents of Tennessee. Tennessee law imposes no liability against petitioner with respect to the life insurance proceeds in issue.

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Respondent determined that petitioner was liable as a transferee for the admitted income tax liability of her deceased husband to the extent of amounts received as beneficiary of policies of insurance on her husband's life. Both petitioner and her deceased husband were residents of Tennessee. Tennessee law imposes no liability against petitioner with respect to the life insurance proceeds in issue. Held: No liability of petitioner to the Government exists under the circumstances of this case. Commissioner v. Stern, 357 U.S. 39 (1958).

1Opinion of the Court

Becky Osborne Hampton, Petitioner, v. Commissioner of Internal Revenue, Respondent

Hampton v. Commissioner

Docket No. 59759

United States Tax Court

30 T.C. 708; 1958 U.S. Tax Ct. LEXIS 150;

June 25, 1958, Filed

Decision will be entered under Rule 50.

Respondent determined that petitioner was liable as a transferee for the admitted income tax liability of her deceased husband to the extent of amounts received as beneficiary of policies of insurance on her husband's life. Both petitioner and her deceased husband were residents of Tennessee. Tennessee law imposes no liability against petitioner with…

2Cases cited6 opinions

  1. United States v. BessSupreme Court of the United States · 1958
  2. Commissioner v. SternSupreme Court of the United States · 1958
  3. Harvey v. HarrisonTennessee Supreme Court · 1891
  4. Third Nat. Bank v. HallCourt of Appeals of Tennessee · 1947
  5. Sparkman-Thompson, Inc. v. ChandlerTennessee Supreme Court · 1931

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