TASHIMA, Senior Circuit Judge.
In 2002, the United States brought an action in district court against taxpayers Robert and Kathleen Haag to reduce to judgment federal income tax liabilities. In her answer, Kathleen Haag asserted an innocent spouse defense under 26 U.S.C. § 6015, which the district court subsequently rejected by granting partial summary judgment to the United States.
Meanwhile, in November 2003, during the pendency of the government action...
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