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022464P.pdf   08/22/2003  Matthew Luxton  v.  USA
   U.S. Court of Appeals Case No:  02-2464
   District of Minnesota   
   Civil case - Federal Tax. While the government would normally
   be limited to the cash surrender value of the life insurance under the
   law governing tax liens, here the government had a right to all of the 
   policy proceeds under collateral agreements signed by plaintiff's 
   decedent and the district court correctly determined the government
   was not limited to the cash surrender value of the policies; under 
   Minnesota law, the assignments granted the IRS an interest in the 
   policy proceeds superior to that of the named beneficiaries.