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ROCKEFELLER v. UNITED STATES

Nos. 83-1192, 83-1281.

718 F.2d 290 (1983)

Winthrop P. ROCKEFELLER, Appellant/Cross Appellee, v. UNITED STATES of America, Appellee/Cross Appellant.

United States Court of Appeals, Eighth Circuit.

Decided October 11, 1983.

Attorney(s) appearing for the Case

Charles C. Owen, Rose Law Firm, A Professional Association, Little Rock, Ark., for appellant/cross appellee.

Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup, William S. Estabrook, Terry L. Fredricks, Attys., Tax Div., Dept. of Justice, Washington, D.C., for appellee/cross appellant; George W. Proctor, U.S. Atty., Little Rock, Ark., of counsel.

Before HEANEY, ROSS and JOHN R. GIBSON, Circuit Judges.

PER CURIAM.

Winthrop P. Rockefeller brought this action for the recovery of penalties assessed by the Internal Revenue Service (IRS) under 26 U.S.C. § 4941. In 1975, Rockefeller purchased all of the stock of Winrock Farms, Inc. from the estate of his father. In 1979, the IRS determined that the purchase was an indirect act of self-dealing between Rockefeller and a charitable trust created in his father's will in violation...

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