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PEARLMAN v. COMMISSIONER OF INTERNAL REVENUE

No. 8951.

153 F.2d 560 (1946)

PEARLMAN v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Third Circuit.

Decided January 30, 1946.

Attorney(s) appearing for the Case

Morris Wolf, of Philadelphia, Pa.(Wolf, Block, Schorr & Solis-Cohen, of Philadelphia, Pa., on the brief), for petitioner.

Bernard Chertcoff, of Washington, D. C. (Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key and J. Louis Monarch, Sp. Assts. to the Atty. Gen., on the brief), for respondent.

Before BIGGS, GOODRICH and McLAUGHLIN, Circuit Judges.

GOODRICH, Circuit Judge.

A taxpayer dies, owing the United States an unpaid balance on income taxes for several years.1 During these years, the taxpayer was insolvent. He had a number of life insurance policies which had been issued to him prior to insolvency. After he became insolvent and up to the time of his death, he continued to pay the premiums on the policies. At the time of death the policies were held by the various insurance...

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