United States v. Pilla

HENLEY,

Senior Circuit Judge.

This is an appeal from the district court’s grant of a motion for summary judgment in favor of the United States. The case centers around a house and the government’s ability to foreclose on it to satisfy the federal tax obligations of its owner. We believe that the Supreme Court’s recent decision in United States v. Rodgers, — U.S. —, 103 S.Ct. 2132, 76 L.Ed.2d 236 (1983), requires a limited remand.

In 1969 appellants Daniel M. Pilla and Carlyn J. Pilla moved into a house on Edg-erton Street in St. Paul, Minnesota. The house and lot were owned solely by Mr. Pilla.

Ev…