United States v. Penn Mut. Life Ins. Co.

JONES, Circuit Judge.

The question presented by this appeal is whether an insurance company, which has issued and delivered a policy of insurance on the life of a patron, is liable under Sec. 3710(b) of the Internal Revenue Code 1 for refusing to turn over the cash surrender value of the policy to the Collector of Internal Revenue upon the latter’s demand under Sec. 3710(a) of the Code because of an unpaid tax liability owing by the insured to the United States, the insured never having elected to receive the cash surrender value of the policy and never having surrendered the policy to the…