United States v. Rodgers et al. (461 U.S. 677)
U.S. Supreme Court · decided May 31, 1983 · Supreme Court Database (Spaeth)
- Citation
- 461 U.S. 677 · 103 S. Ct. 2132
- Decided
- May 31, 1983
- Term
- October Term 1982
- Vote
- 5–4
- Majority author
- Justice Brennan
- Issue area
- Federal Taxation
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
<opinion type="majority"> <author id="b738-5">Justice Brennan</author> <p id="Ate">delivered the opinion of the Court.</p> <p id="b738-6">These consolidated cases involve the relationship between the imperatives of federal tax collection and rights accorded by state property laws. Section 7403 of the Internal Revenue Code of 1954, 26 U. S. C. §7403 (1976 ed. and Supp. V), authorizes the judicial sale of certain properties to satisfy the tax indebtedness of delinquent taxpayers. The issue in both cases is whether § 7403 empowers a federal district court to order the sale of a family home in which a delinquent taxpayer had an interest at the time he incurred his indebtedness, but in which the taxpayer’s spouse, who does not owe any of that indebtedness, also has a separate “homestead” right as defined by Texas law. We hold that the statute does grant power to order the sale, but that its exercise is limited to some degree by equitable discretion. We also hold that, if the home <em>is </em>sold, the nondelinquent spouse is entitled, as part of the distribution of proceeds required under § 7403, to so much of the proceeds as represents complete compensation for the loss of the homestead estate.</p> <p id="b738-7">I</p> <p id="b738-8">A</p> <p id="b738-9">Section 7403 provides in full as follows:</p> <blockquote id="b738-10">“(a) Filing. — In any case where there has been a…
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