United States v. Bernice H. Shanbaum

GOLDBERG, Circuit Judge:

The United States brought this suit to reduce to judgment income tax and transferee liability assessments that it had made against Bernice H. Shanbaum and her husband, Theodore B. Shanbaum, and to foreclose upon tax liens that it had asserted against the Shanbaums’ real estate. The assessments were made after the government and the Shanbaums entered into agreed decisions in the United States Tax Court. The income tax liability assessments stemmed from deficiencies that the Shanb-aums had incurred from eight years of underpayments on their joint income tax returns. The…