Court of Appeals for the Fifth Circuit July 6, 1981, 79-3358, 80-1020 (United States v. Lucille Mitzy Bosco Rogers, Individually and as Surviving Spouse of Philip S. Bosco)

JERRE S. WILLIAMS, Circuit Judge:

This case presents the interesting question whether the federal government may foreclose a federal tax lien on the Texas homestead of a delinquent taxpayer in order to satisfy the delinquent taxpayer’s tax liability, when the taxpayer’s spouse, also having an interest in the homestead, has no federal tax liability.

I.