Barr v. United States

When a court allocates the proceeds from a sale pursuant to 26 U.S.C. § 7403, which allows district courts to order a sale of a delinquent taxpayer’s property to satisfy a federal tax lien, even if the property is co-owned with another individual who does not owe taxes, and provides that the proceeds of the sale should be allocated "according to the interests of the parties and of the United States," must the court take into account the additional value of the survivorship right of the spouse with the longer life expectancy and any other asymmetrical rights or must it instead allocate the proceeds equally to each party in every situation?