UNITED STATES of America
v.
Anthony J. J. A. WILSON, Hedwig C. Wilson, Massachusetts Mutual Life Insurance Company and Travelers Insurance Company,
Massachusetts Mutual Life Insurance Company, Appellant.
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
A. Peter Quinn, Jr., Springfield, Mass. (John P. Nugent, Jersey City, N. J., on the brief), for appellant Massachusetts Mut. Life Ins. Co.
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., David M. Satz, Jr., U. S. Atty., on the brief), for appellee.
Before BIGGS, Chief Judge, and McLAUGHLIN, KALODNER, STALEY, HASTIE, GANEY and SMITH, Circuit Judges.
United States Court of Appeals Third Circuit.
BIGGS, Chief Judge.
This action was brought by the United States under Section 7403 of the Internal Revenue Code of 1954,1 to collect for unpaid income taxes by foreclosure of a tax lien on the interest of delinquent taxpayer, Anthony Wilson, in certain unmatured insurance policies. Defendants in the proceeding below were the taxpayer, his wife, the Travelers Insurance Company, and the Massachusetts Muutal Life Insurance Company ("Massachusetts...
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