of these issues and therefore adopt the dis trict court’s thoughtful reasoning with regard to the Rodgers factors. We therefore AFFIRM the judgment of the district court. ALICE M. BATCHELDER, Chief Judge, concurring in part and dissenting in part. I concur with the majority opinion’s conclusion that foreclosure of the residence of Charles and Carolyn Barr was appropriate pursuant to 26 U.S.C. § 7403. The majority opinion, however, conflates two distinct issues: (1) whether foreclosure is appropriate, in order to satisfy the tax obligations of her husband, Charles Barr; and (2) the proper distribution of the sales proceeds post-foreclosure. The majority opinion appears to conclude that the district court was correct because it was also correc S.Ct. 1414, 152 L.Ed.2d 437 (2002) (<HOLDING>). The power to order the sale, however, “is
holding that under michigan law tenants in the entirety possess sufficient property interests for federal tax liens to attach holding that federal government may not under michigan law attach lien to entireties property to satisfy individual tax liability of one spouse holding that congress has made it clear in amending section 522 that a lien will be deemed to impair an exemption even when there is no equity in the property if the sum of all the liens on the property and the hypothetical value of the exemption without liens exceeds the value of the debtors interest in the property in the absence of liens holding that no tax liens may attach to property after the fdic acquired title holding that state legislature should determine whether to cure discriminatory tax by enforcing tax as to all or forgiving tax in its entirety