Francis moved in with her mother, Beatrice, when Beatrice's health started to fail. Francis cared for her mother as a devoted child and never expected anything in return. When Beatrice needed to move to a nursing home, she legally transferred the home to Francis for $1,000 and "other valuable consideration."

The house had cost Beatrice $50,000 many years ago, and on the date of the transfer it was valued at $150,000. At the time of the transfer, Beatrice was insolvent, as she owed the IRS $250,000 in back taxes and interest for 1990 to 2008. A few months after the transfer of the house, the IRS filed a notice of Federal tax lien for Beatrice's unpaid taxes. The IRS has filed against Francis for $150,000 of her mother's taxes, as Francis is in possession of the only valuable asset Beatrice has owned. Can the IRS collect from Francis?