AUGUSTUS N. HAND, Circuit Judge.
The taxpayer was the owner of two participating insurance policies in the Equitable Life Assurance Society. The dividends paid thereon could either be withdrawn or applied to the reduction of the premiums due. On or about August 4, 1939, the taxpayer owed the insurance company $18,844.33 which he had borrowed against the security of his policies. On that date he executed two applications for loans totalling $1,862.27 and the company...
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