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U.S. v. GIBBONS

No. 94-1330.

71 F.3d 1496 (1995)

UNITED STATES of America, Plaintiff-Appellee, v. David GIBBONS, Defendant, and Betty J. Gibbons, Defendant-Appellant.

United States Court of Appeals, Tenth Circuit.

December 1, 1995.

Attorney(s) appearing for the Case

Fred M. Hamel, Denver, Colorado, for Defendant-Appellant Betty J. Gibbons.

Robert W. Metzler, Attorney, Tax Division (Loretta C. Argrett, Assistant Attorney General, and William S. Estabrook, Attorney, Tax Division; of counsel: Henry Lawrence Solano, United States Attorney, with him on the brief), Department of Justice, Washington, D.C., for Plaintiff-Appellee.

Before HENRY and LOGAN, Circuit Judges, and ELLISON, District Judge.

LOGAN, Circuit Judge.

This case involves a dispute between the United States Internal Revenue Service (IRS) and Betty J. Gibbons, the ex-wife of taxpayer David Gibbons. The IRS brought suit pursuant to I.R.C. §§ 7401-7403, to reduce to judgment federal tax assessments against David Gibbons and to foreclose federal tax liens against real property in which he held an interest. The district court found that despite a dissolution of marriage decree awarding...

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