Hampton v. Commissioner
United States Tax Court
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
Bruce, Judge:
The respondent determined that the petitioner was liable as a transferee of assets of the Estate of Forrest L. Osborne, deceased, for unpaid income taxes and additions to tax, plus interest thereon, due from the estate of the deceased as follows:
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The only question for decision is whether the petitioner is liable as a transferee for the deficiencies in income tax and additions to tax plus interest thereon due from Forrest L. Osborne for the years 194-1 to 1947, inclusive, and 1949, to the extent of the proceeds of certain insurance policies on the life of Osborne,…
2Cases cited5 opinions
- United States v. BessSupreme Court of the United States · 1958
- Commissioner v. SternSupreme Court of the United States · 1958
- Harvey v. HarrisonTennessee Supreme Court · 1891
- Third Nat. Bank v. HallCourt of Appeals of Tennessee · 1947
- Sparkman-Thompson, Inc. v. ChandlerTennessee Supreme Court · 1931
3Cited by3 opinions
- Bingham v. CommissionerUnited States Tax Court · 1958
- Bingham v. CommissionerUnited States Tax Court · 1958
- Hampton v. CommissionerUnited States Tax Court · 1958