In an action involving the Government's attempts to collect unpaid taxes assessed against a homeowner, seeking a judicial sale of the home, the district court's judgment, that a forced sale would be inequitable and order that the homeowner make monthly rent payments to the Government instead, is: 1) affirmed as to the district court’s authority to consider whether the property should be subject to a forced sale; but 2) vacated and remanded for recalculation of the ownership interests in the property and reconsideration of the equitable factors weighing for and against a sale.