BUFFINGTON, Circuit Judge.
As we hold that under the policies here concerned the sons of Mrs. McKelvy, the taxpayers, were the owners thereof, and that their mother had no right to change the beneficiary or power to surrender or to borrow on the security of such policies, it follows that the first question here involved is: "Are the proceeds of policies of life insurance issued subject to the laws of Pennsylvania prior to the effective date of the Revenue Act of 1918...
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