United States v. Solomon Fried and Ilene Fried, and New York Life Insurance Company

This is an appeal by Solomon and llene Fried from a judgment of the United States District Court for the Eastern District of New York, Bruchhausen, J., granting the Government’s motion for summary judgment. Solomon Fried is the insured on eight insurance policies issued by the New York Life Insurance Company. Each of the policies designates his wife, llene Fried, as the beneficiary and each reserves to Solomon Fried the right to change the beneficiary and the right to withdraw the cash surrender value. In 1955 the Government, alleging income tax deficiencies against Fried, brought an action…