was timely assessed followed by a timely court proceeding resulting in a judgment for the United States. The United States is not time-barred from bringing the present action to enforce assessment liens precisely because the United States previously obtained a judgment against J. Brickman as the transferee of the original taxpayer. The United States can enforce that judgment at any time. Ettelson, 159 F.2d at 196. The fact that J. Brickman was a transferee of the original taxpayer and not the original taxpayer does nothing to undermine this determination which is well supported by precedent. See, e.g., Moyer v. Mathas, 458 F.2d 431, 434 (5th Cir.1972) (allowing foreclosure suit brought twenty years after timely lien); United States v. Overman, 424 F.2d 1142, 1147 (9th Cir.1970) (<HOLDING>); Hodes, 355 F.2d at 748-49 (finding that the
holding that any property in which the taxpayer has any right title or interest is subject to foreclosure proceeding including property in which others claim an interest so long as all persons having liens or claiming any interest in the property are joined as parties to the suit holding state immune from suit brought in state court holding that a prior suit and a subsequent suit between the same parties did not involve the same claim because the evidence necessary to sustain the subsequent suit was insufficient to entitle the plaintiff to relief in the prior suit holding a suit against an agency of the state is a suit against the state holding that foreclosure suit brought six years after judgment in timely suit was not timebarred because tax liens are enforceable at any time