United States v. Continental Nat. Bank & Trust Co.

SPARKS, Circuit Judge.

This appeal presents the question of the liability of the distributees under the will of James Duggan, deceased, for a tax liability alleged to have been due from him as transferee of the assets of a dissolved corporation. The Government filed suit in equity against the testamentary trustee and beneficiaries under the will of Duggan, deceased. Its bill of complaint was dismissed, and it is from the order of dismissal that this appeal is prosecuted.

’ The facts relied upon to sustain the prayer for relief against the distributees were substantially as follows: James Duggan…