Frances M. Cole v. Commissioner of Internal Revenue

SANBORN, Circuit Judge.

The Commissioner of Internal Revenue on July 29, 1957, advised Frances M. Cole that the determination of the income tax liability of her husband, Charles N. Cole, of Joplin, Missouri, for the years 1951, 1952 and 1953 disclosed deficiencies and penalties aggregating $46,049.94, and that $12,000 of that amount had been as sessed against her as transferee of assets of her husband. Mrs. Cole petitioned the Tax Court for a redetermination of her asserted liability as a transferee. The court sustained the Commissioner. Mrs. Cole asks that we review and reverse the decision…