Conway v. Imperial Life Ins. Co.

HAMITER, Justice.

On the present appeal, this case presents the single question of whether the claim of the United States Government for taxes due by an insurance company now in receivership should be paid by preference and priority, out of funds held by the receiver, over the policy obligations of that company.

The issue, which was resolved against the United States by the district court, has the following described factual background :

For a number of years prior to April 1, 1937, the Imperial Protective Union and the American Benefit Association, which were organized under the laws of…