No. 23-3751 ___________________________

United States of America

lllllllllllllllllllllPlaintiff - Appellee

v.

Ronald E. Byers; Deanna L. Byers

lllllllllllllllllllllDefendants - Appellants

Hennepin County, Minnesota

lllllllllllllllllllllDefendant ____________

Appeal from United States District Court for the District of Minnesota ____________

Submitted: October 22, 2024 Filed: April 7, 2025 ____________ Before LOKEN, SMITH, and GRASZ, Circuit Judges. ____________ SMITH, Circuit Judge. Ronald E. Byers (Ronald) owes the United States (government) for unpaid income taxes, interest, and penalties. The government brought suit to enforce its federal tax liens through the judicial sale of Ronald’s home, which he alon