UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 20-1161

In re: LARRY EDWARD WOOD; JESSICA ANN WOOD,

Debtors. ------------------------------ LARRY EDWARD WOOD; JESSICA ANN WOOD,

Plaintiffs – Appellees, v. UNITED STATES DEPARTMENT OF HOUSING & URBAN DEVELOPMENT (HUD),

Defendant - Appellant.

Appeal from the United States District Court for the Southern District of West Virginia, at Beckley. Irene C. Berger, District Judge. (5:19-cv-00302)

Submitted: March 12, 2021 Decided: April 7, 2021

Before WILKINSON, NIEMEYER, and QUATTLEBAUM, Circuit Judges.

Reversed and remanded by published opinion. Judge Wilkinson wrote the opinion, in which Judge Niemeyer and Judge Quattlebaum joined. Richard E. Zuckerman, Principal Deputy Assistant Attorney General, Bruce R. Ellisen, Bethany B. Hauser, Tax Division, UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C.; Michael B. Stuart, United States Attorney, OFFICE OF THE UNITED STATES ATTORNEY, Charleston, West Virginia, for Appellant. William R. Wooton, W