United States v. Nelle A. Hoper

SWAIM, Circuit Judge.

This is an action to enforce a lien of the United States for income tax upon the property of the delinquent taxpayer to the payment of such tax. The question presented is whether a government lien for delinquent income taxes obtained pursuant to Section 3670, 26 U.S.C.A. (I.R.C.1939), in the lifetime of the taxpayer against the taxpayer’s interest in life insurance policies on his life, i. e., their cash surrender values, the policies not being payable to the taxpayer or his estate, survives his death as against the designated beneficiaries. The policies in question were…