United States v. Wilbert Schneider

SACHS, District Judge.

This action was brought by the United States to reduce to judgment federal income tax liabilities of Wilbert and Virginia Schneider, husband and wife, arising out of obligations for three years in which they filed joint returns; the Government also sought to foreclose tax liens on certain real estate. Joined in the action were transferees of the real estate. Defendants below contested the validity of the liens asserted on claims separately assessed in different amounts against the Schneiders individually. Separate lien notices had been filed, on different dates, and…