United States v. Metropolitan Life Insurance
Court of Appeals for the Eleventh Circuit
1Opinion of the Court
JOHNSON, Circuit Judge:
This appeal arises from the grant of summary judgment in favor of the government and against an insurance company in the amount of $20,898.79 under 26 U.S.C.A. § 6332(c)(1), representing the unelected cash withdrawal value of an annuity contract owned by a delinquent taxpayer, and $10,449.40 under 26 U.S.C.A. § 6332(c)(2), representing a 50% penalty for failing to honor the government’s tax levy on the annuity contract without reasonable cause. We affirm.
I. FACTS
On December 22, 1975, Fitzhugh Lee Jackson submitted an application to purchase an annuity contract from…
2Cases cited10 opinions
- United States v. National Bank of CommerceSupreme Court of the United States · 1985
- United States v. BessSupreme Court of the United States · 1958
- United States v. Sterling National Bank & Trust Company of New York, and Third-Party v. Charles S. Smith, Third-PartyCourt of Appeals for the Second Circuit · 1974
- The State Bank of Fraser, Cross-Appellant v. United States of America, Cross-AppelleeCourt of Appeals for the Sixth Circuit · 1988
- United States v. Metropolitan Life Ins. Co.Court of Appeals for the Second Circuit · 1942
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3Cited by16 opinions
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- United States v. Stephen C. HemmenCourt of Appeals for the Ninth Circuit · 1995
- United States v. HoskingCourt of Appeals for the Seventh Circuit · 2009
- Kane v. Capital Guardian Trust Co.Court of Appeals for the Tenth Circuit · 1998
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