United States v. BANKERS'NATIONAL LIFE INSURANCE CO.

WORTENDYKE, District Judge.

This action against a life insurance corporation to foreclose an alleged tax lien upon the interest of the insured named in each of three policies issued by the company, presents the question whether the insured had any ascertainable property in each of the policies to which the asserted lien could attach.

Jurisdiction is conferred upon the Court by 26 U.S.C. § 7403. The statutory conditions precedent to the institution of the action have been complied with. Tax liens are claimed to have arisen under 26 U.S.C. § 6321. There was due to the plaintiff from the taxpayer…