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U. S. v. UNION CENTRAL LIFE INS. CO.

No. 52.

368 U.S. 291 (1961)

UNITED STATES v. UNION CENTRAL LIFE INSURANCE CO.

Supreme Court of United States.

Decided December 18, 1961.

Attorney(s) appearing for the Case

I. Henry Kutz argued the cause for the United States. With him on the briefs were Solicitor General Cox, Assistant Attorney General Oberdorfer and Fred E. Youngman.

H. William Butler argued the cause and filed briefs for respondent.

Opinion of the Court by MR. JUSTICE BLACK, announced by MR. JUSTICE FRANKFURTER.

Robert G. Peters, Jr., and his wife, of Oakland County, Michigan, failed to pay their 1952 federal income taxes. In January 1954 an assessment for this delinquency was filed in the Internal Revenue Collector's Office at Detroit, Michigan, at which time a lien arose "in favor of the United States upon all property" of the two delinquent taxpayers...

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