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 alone owns but shares with his wife, Deanna L. Byers (Deanna). All parties agreed that the government may sell the home and apply some of the proceeds to Ronald’s tax debt. But the Byerses argued that Deanna is entitled to half of the proceeds of the judicial sale because the property is the marital homestead. The parties filed cross-motions for summary judgment. The district court1 granted the government’s motion and denied the Byerses’ motion, holding that Deanna lacked a property interest in the home and was not entitled to any portion of the sale proceeds. On appeal, the Byerses again argue that Deanna is entitled to half of the proceeds of the judicial sale. We affirm.

I. Background Ronald owns property located at 16808 Prospect Place in Wayzata, Minnesota (Wayzata Property). Ronald is the sole titleholder of the Wayzata Property. Ronald acquired it by a personal representative’s deed in 1990; he recorded the deed in Hennepin County on June 26, 1990. Hennepin County classifies the Wayzata Property as a homestead. Approximately two years after acquiring the Wayzata Property, Ronald and Deanna married.

In February 1994, Ronald and Deanna, as husband and wife, executed a new mortgage on the Wayzata Property in the amount of $59,932, which paid off the existing mortgage. Ronald and Deanna contributed equally to the mortgage payments until the mortgage was fully satisfied in 2009. But, at all times, Ronald has remained the sole titleholder to the Wayzata Property.

1 The Honorable Patrick J. Schiltz, Chief Judge, United States District Court for the District of Minnesota.

-2- Ronald owes the government $327,419.11 for unpaid income taxes, interest, and penalties. The government made multiple tax assessments against Ronald. As a result, multiple federal tax liens attached to his property interests, including in the Wayzata Property. The government brought suit to reduce Ronald’s tax assessments to judgment and to enforce its liens by way of a judicial sale of the property. See 26 U.S.C. § 7403. In addition to Ronald, the government named two other defendants who may claim an interest in the Wayzata Property: Deanna and Hennepin County. See id. § 7403(b). Hennepin County and the government stipulated that any lien interest that Hennepin County has in the Wayzata Property as a result of unpaid property taxes is superior to the government’s lien interest in the property as a result of unpaid income taxes. Although the Byerses agreed that the government may sell the Wayzata Property, they argued that Deanna is entitled to half of the sale proceeds.

The government and the Byerses filed cross-motions for summary judgment. The government argued tha