UNITED STATES of America, Appellant.
v.
Cornelius W. SULLIVAN et al.
United States Court of Appeals Third Circuit.https://leagle.com/images/logo.png
Argued April 5, 1963.
Submitted October 12, 1963.
Decided April 10, 1964.
Attorney(s) appearing for the Case
John B. Jones, Jr., and Joseph Kovner, Attys., Dept. of Justice, Washington, D. C. (Louis F. Oberdorfer, Asst. Atty. Gen., Lee A. Jackson, Michael A. Mulroney, Attys., Dept. of Justice, Washington, D. C., Joseph S. Ammerman and Gustave Diamond, U. S. Attys., Thomas J. Shannon, Asst. U. S. Atty., on the brief), for appellant.
Alexander Black, Buchanan, Ingersoll, Rodewald, Kyle & Buerger, Pittsburgh, Pa. (John M. Reed, Reed & Egler, Pittsburgh, Pa., John H. Filer, Hartford, Conn., on the brief), for appellee Aetna Life Ins. Co.
Gilbert J. Helwig, Pittsburgh, Pa. (J. Tomlinson Fort, Reed, Smith, Shaw & McClay, Pittsburgh, Pa., E. H. McVitty, Toronto, Canada, on the brief), for appellee Manufacturers Life Ins. Co.
Thomas Lewis Jones, White, Jones & Gregg, formerly White & Jones, Pittsburgh, Pa., for General American Life Ins. Co.
K. Martin Worthy, Glenn L. Archer, Jr., Hamel, Morgan, Park & Saunders, Washington, D. C., for Life Insurance Ass'n of America, amicus curiae.
Before BIGGS, Chief Judge, and McLAUGHLIN, KALODNER, STALEY, HASTIE, GANEY and SMITH, Circuit Judges
United States Court of Appeals Third Circuit.
BIGGS, Chief Judge.
The United States brought this action under Section 7403 of the Internal Revenue Code of 1954,1 to foreclose a tax lien on unmatured insurance policies. Defendants in the proceeding below in addition to the delinquent taxpayers, Cornelius W. Sullivan and his wife, Mary E. Sullivan, were the Aetna Life Insurance Company ["Aetna"], and the Manufacturers Life Insurance Company...
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