(before death, taxpayer failed to timely pay assessed taxes; taxpayer and wife owned property as tenants by the entirety; taxpayer and wife conveyed property to wife for $1; IRS filed tax lien against property shortly thereafter; taxpayer died, but formal estate never submitted to probate; one year later, wife passed away; co-executors of wife’s estate brought formal probate proceedings; IRS sent notice of tax lien to co-executors; administrative appeal initiated by estate contesting assessment, IRS prevailed; co-executors conveyed property to son (also co-executor) for $1; son sold property to third party netting proceeds of $313,206.94, which son lost in stock market; IRS brought suit to enforce its lien; competing summary judgments filed; court held first that probate exception argued by co-executors to federal jurisdiction did not apply to federal question raised by IRS and IRS’s collection efforts were timely because instituted within three years of tax filings; court held tax lien continued to encumber one-half of property because tenancy by entirety intentionally terminated by joint conveyance of property to wife; court rejected co-executors argument that wife was bona fide purchaser because payment of $1 not adequate consideration for sale; court found co-executors personally liable as fiduciaries for tax lien because conveyance of property to son rendered estate insolvent after co-executors had knowledge of lien).