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U.S. v. SOLHEIM

No. 91-1667.

953 F.2d 379 (1992)

UNITED STATES of America, Appellee, v. Frederick S. SOLHEIM; Robert A. Solheim; John S. Solheim; National Bank of Commerce Trust and Savings Association of Lincoln, Trustee of the Selmer A. Solheim Trust; State of Colorado, Department of Revenue, Appellants.

United States Court of Appeals, Eighth Circuit.

Decided January 7, 1992.

Attorney(s) appearing for the Case

J.L. Spray, Lincoln, Neb., argued, for appellants.

Robert L. Baker, Dept. of Justice, Washington, D.C., argued (Gary R. Allen and David I. Pincus, Dept. of Justice, Washington, D.C. and Ronald D. Lahners, U.S. Attorney, Omaha, Neb., appeared on brief), for appellee.

Before LAY, Chief Judge, and ARNOLD, Circuit Judge and STUART, Senior District Judge.

STUART, Senior District Judge.

We are called upon to determine whether the taxpayer's renunciation, under state law, of his interest in a trust extinguished a federal tax lien attached to the interest under 26 U.S.C. § 6321 (1988). The district court1 held that the taxpayer's renunciation did not extinguish the lien. Upon the taxpayer's appeal, we affirm.

I.

The taxpayer, Frederick S. Solheim, was the beneficiary...

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