Metropolitan Life Ins. Co. v. United States

HAMILTON, Circuit Judge.

During the years 1929 and 1930, appellant, an insurance corporation organized under the laws of the State of New York, by assignment' acquired three mortgages, upon separate parcels of real estate, located in Detroit, Michigan. Each mortgage contained an acceleration clause and a provision which gave the mortgagee the right to sell the premises in event of default, with the King-Kelly Corporation as debtor. The mortgage assignments and conveyances ,were duly recorded.

On August 17, 1932, prior to foreclosure, an assessment for corporation income taxes for the year 1930…