Legal Opinion

Muller v. Commissioner

United States Tax Court

Decided April 21, 1948No. Docket No. 13002PublishedCited by 27 opinions

Transferee Liability -- State Exemptions From Execution. -- A widow receiving property from her husband's estate exempt from execution in her hands under state law is a transferee and liable as such for Federal taxes due from the decedent.

1Opinion of the Court

OPINION.

Murdock, Judge:

The Commissioner determined that the petitioner is liable, as transferee, for income taxes of her deceased husband, Nicholas W. Muller, for the period from January 1, to June 18, 1943, in the amount of $1,048.81. The petitioner does not contest the amount of the taxes, but contends that she is not liable as a transferee for those taxes.

The stipulation of facts is adopted as the findings of fact and, in addition, it is found from the testimony that the fair market value of a 1941 Chrysler sedan, at the time it was received by this petitioner, was not in excess of $450,…

2Cited by27 opinions

  1. Ruth Halle Rowen, Ethel F. Halle, and Edward Halle v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1954
  2. Rowen v. CommissionerUnited States Tax Court · 1952
  3. Estate of Nitto v. CommissionerUnited States Tax Court · 1949
  4. Bales v. CommissionerUnited States Tax Court · 1954
  5. Stoumen v. CommissionerUnited States Tax Court · 1957

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