Wood (D) executed an agreement with her husband to sell a home and apply the proceeds to the mortgage and a tax lien. The property was sold at public auction, but the price was less than the statutorily required 2/3rds of the appraisal. A right of redemption was created within one year from the day of the sale wherein D contracted to sell the property. The IRS then put a notice of levy on the property. At a trial over that levy, the district court held that the IRS was a creditor beneficiary of the agreement between D and her husband. D appealed.

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