We wonder why Heuser, rather than the I.R.S., filed an appeal?  Consider the following. 

     We surmise that the tax liens in question were to secure payment of unpaid corporate withholding taxes.  Under the Internal Revenue Code, owners of a corporation are individually liable for 100% of unpaid corporate withholding taxes (notwithstanding the state law that shareholders are not liable for the debts of the corporation in which they own shares).  Thus, application of the proceeds of the sale of the broadcast licenses to the tax debt would have reduced Heuser's individual liability to the I.R.S, and Heuser would therefore would like to see the I.R.S. prevail. 

     However, the first sentence of the opinion tells us that Heuser was a "guarantor of several corporations."  Does that mean that he guaranteed repayment of the loans to MLQ?  If so, limited liability as a corporate shareholder would not protect him against a claim by MLQ for any deficiency following the application of the proceeds of the sale of the broadcast licenses to the debt.  Thus, why would he care whether the proceeds went to the I.R.S. or to MLQ?  In either case, he would be liable for whatever debt remained unpaid. 

     Perhaps he didn't guarantee all of the loans made by MLQ.