BRUNETTI, Circuit Judge:
Plaintiff-Appellee Dorothy Schmit ("Schmit") brought an action in the federal district court pursuant to I.R.C. § 7426 to enjoin Defendant-Appellant United States from levying against her home for unpaid taxes and to adjudge the tax lien wrongful and order it released. The taxes are owed by Schmit's now deceased former husband, Joseph Saligoe ("Saligoe").
Schmit's home was purchased entirely with Schmit's separate property, but...
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