United States v. Wilson

BIGGS, Chief Judge.

This action was brought by the United States under Section 7403 of the Internal Revenue Code of 1954,1 to collect for unpaid income taxes by foreclosure of a tax lien on the interest of delinquent taxpayer, Anthony Wilson, in certain unmatured insurance policies. Defendants in the proceeding below were the taxpayer, his wife, the Travelers Insurance Company, and the Massachusetts Muutal Life Insurance Company (“Massachusetts Mutual”). From adverse determinations in the court below, the insurers have appealed on separate questions. The opinion on the appeal of the Travelers…