THOMPSON, District Judge.
This is an action by the United States against Albert Salerno to recover judgment for unpaid income taxes due, and against the Mutual Life Insurance Company of New York to foreclose a lien against the cash surrender value of a life insurance policy written on the life of defendant Albert Salerno, and owned by him. Salerno defaulted, and on October 5, 1962, default judgment was taken against him for the tax deficiency. Mutual Life answered...
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