OPINION.
FORRESTER, Judge:
The Commissioner determined that petitioner was liable under section 311, I. R. C. 1939, as a transferee for unpaid income taxes for the year 1952 of William C. Myers, Sr., deceased, in the amount of $527.08. The sole issue before us is whether petitioner is so liable by virtue of having received as beneficiary the proceeds of a policy of insurance upon the life of the deceased.
All of the facts have been stipulated...
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