Ann W. Bowlin v. Commissioner of Internal Revenue

This cause came on to be heard upon the petition of the taxpayer, Ann W. Bowlin, for review of the decision of the Tax Court of the United States, holding petitioner liable as transferee of assets of her husband with respect to deficiencies in income taxes and additions to tax for fraud for the years 1942 through 1947.

We agree with the decision of the tax court, for the reasons stated in its opinion, that the transfers by her husband to the petitioner, including the full cash surrender value of certain insurance policies on his life, rendered the husband insolvent and, consequently, the…