United States v. Sterkowicz

OPINION

NAPOLI, District Judge.

This is an action brought by the United States pursuant to 26 U.S.C. § 7403(a)1, to foreclose certain tax liens *706upon life insurance policies issued upon the life of the defendant-taxpayer Walter Sterkowiez by the defendant life insurance companies. The liens arose, pursuant to Section 6321 of the Internal Revenue Code,2 upon nonpayment of a marijuana transfer tax.

All of the defendant life insurance companies are authorized to, and do business within the judicial district of this court. The defendant taxpayer formerly resided with the judicial district of this…