Othello Washington and Ellen P. Washington v. United States

BOREMAN, Circuit Judge:

This is an appeal from a judgment of the district court ordering the public sale of certain real estate owned by taxpayer, Othello Washington, in satisfaction of the government’s lien for excise tax deficiencies plus delinquency penalties and interest under federal wagering tax statutes. 1 The government’s lien arises from a wagering tax assessment against Othello Washington imposed pursuant to Internal Revenue Code of 1954, 26 U.S.C. § 4401 (1964 ed.), plus a fifty percent fraud penalty assessed pursuant to 26 U.S.C. § 6653(b) (1964 ed.).

The complaint alleged that…