No. 90-5298.

936 F.2d 373 (1991)

UNITED STATES of America, Appellant, v. Cecil BIERBRAUER and Judy Bierbrauer, Appellees.

United States Court of Appeals, Eighth Circuit.

Decided June 19, 1991.

Attorney(s) appearing for the Case

William Estabrook, Dept. of Justice, Washington, D.C. (Shirley Peterson, Asst. U.S. Atty. Gen., Gary Allen, Charles Brookhart and Rosemary Schrauth, Dept. of Justice, Washington, D.C., on brief), for appellant.

Stanley Mosio, St. Paul, for appellees.

Before LAY, Chief Judge and McMILLIAN and ARNOLD, Circuit Judges.

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,1 the house was owned by both husband and wife as joint tenants. The...

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