Court of Appeals for the Second Circuit August 27, 1997, 1709, Docket 96-5122 (In Re Harriet Bourque, Debtor. Harriet Bourque v. United States of America Internal Revenue Service)

CALABRESI, Circuit Judge.

Following a seven-year battle with cancer, Harriet Bourque’s husband died and left her with slightly more than $108,000 in life insurance proceeds. Mrs. Bourque was also left with substantial liabilities for tax deficiencies that were incurred during the last years of her husband’s life.