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IN RE TAFFI

Nos. 94-55011, 94-55019.

68 F.3d 306 (1995)

In re Donald TAFFI; Madelaine Taffi, Debtors. Donald TAFFI; Madelaine Taffi, Plaintiffs-Appellants, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided October 10, 1995.

Attorney(s) appearing for the Case

A. Lavar Taylor, Santa Ana, California, for plaintiffs-appellants.

Paula K. Speck, United States Department of Justice, Tax Division, Washington, D.C., for defendant-appellee.

Before: WALLACE, Chief Judge, KOZINSKI and RYMER, Circuit Judges.

Opinion by Chief Judge Wallace; Dissent by Circuit Judge KOZINSKI.

WALLACE, Chief Judge:

The Taffis (Debtors) appeal from the district court's judgment in favor of the Internal Revenue Service (IRS). The district court held that for purposes of valuing a secured tax lien on the residence the Debtors will retain, the residence should be valued at its "fair market" value and that "hypothetical costs of sale" should not...

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