MEMORANDUM OF OPINION
WESLEY E. BROWN, Chief Judge.
This is a civil action in which the United States seeks to foreclose certain federal tax liens against the interest of Ralph G. Hershberger in property owned in joint tenancy by him and his wife. The wife, Esther, is resisting the foreclosure on the basis of the Kansas homestead exemption. The parties have stipulated to all the facts pertinent to the Court's decision, and the action is now before us on...
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