Tyson v. Commissioner of Internal Revenue

The appeal relates to the interpretation of section 311(a) (1), (f) of the Internal Revenue Code and poses the question:

Does the Commissioner of Internal Revenue have authority to hold a wife-beneficiary of a life insurance policy liable for unpaid income taxes of a deceased spouse as transferee of her husband’s assets?

The Tax Court answered in the affirmative and sustained a deficiency assessment by the Commissioner.

After consideration of the records, briefs, and arguments of counsel for the parties, we believe the decision should be reversed.

The statutes involved in the adjudication of the…