of tenants by the entirety. See Mazzara, 530 F.Supp. at 1385-86. While Mrs. Klimek may have some interest in the Golf Club Drive property (although clearly not an interest by the entireties), it is clear that § 7403 mandates, subject to limited exceptions, the sale of not only her delinquent taxpayer husband’s interest in the levied property, but of the whole property. See Rodgers, 461 U.S. at 693-94, 103 S.Ct. at 2142 (“[W]e must read the statute [§ 7403] to contemplate, not merely the sale of the delinquent taxpayer’s own interest, but the sale of the entire property (as long as the United States has any ‘claim or interest’ in it), and the recognition of third-party interests through the mechanism of judicial valuation and distribution.”); id. at 692 n. 18, 103 S.Ct. at 2142 n. 18 (<HOLDING>) (quoting § 7403(a) & (b)); see Mazzara, 530
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 that scope of property subject to forfeiture is defined by the instrument creating an interest in the property holding that plaintiffs may have a property interest in real property 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 a taxpayers interest as an heir to his mothers estate constituted property or a right to property to which  federal tax liens attached  despite his exercise of the prerogative state law accorded him to disclaim the interest retroactively