ARNOLD, Circuit Judge.
This appeal involves the United States' efforts to force the sale of a house occupied by a Minnesota couple in order to satisfy a tax debt owed by the husband. Title to the house, located at 17370 Hiawatha Beach Drive, Wyoming, Minnesota, is currently in the name of Judy Bierbrauer. However, in 1977, when Cecil Bierbrauer's tax delinquency accrued,
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