Montgomery v. Commissioner

Oroville Montgomery v. Commissioner.

Montgomery v. Commissioner

Docket No. 10852.

United States Tax Court

1947 Tax Ct. Memo LEXIS 106; 6 T.C.M. (CCH) 983; T.C.M. (RIA) 47240;

August 25, 1947

Harold I. Cole, Esq., and Milton Levitan, Esq., for the petitioner. J. Frost Walker, Jr., Esq., for the respondent.

OPPER

Memorandum Findings of Fact and Opinion

OPPER, Judge: This proceeding seeks a redetermination of a deficiency for 1939 of $25,946.33 in income tax, together with penalty of $6,486.58, against petitioner as transferee.

The broad issue relates to petitioner's liability as transferee of her…