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U.S. v. BRYANT

No. 93-2510.

15 F.3d 756 (1994)

UNITED STATES of America, Plaintiff-Appellee, v. Kermit BRYANT; Frances Bryant; The Bryant Family Trust; and Phil Bryant, Renee B. Stacks, Rhonda Frederick, and Debbie Herndon, as Trustees for the Bryant Family Trust, Defendants-Appellants.

United States Court of Appeals, Eighth Circuit.

Decided February 1, 1994.

Attorney(s) appearing for the Case

Counsel who presented argument on behalf of the appellants was Richard Hatfield of Little Rock, Arkansas. The names of Richard F. Hatfield and Thomas J. Swearingen of Little Rock, Arkansas, appear on the brief of the appellants.

Counsel who presented argument on behalf of the appellee was David Shuster of Washington, DC. The names of Michael L. Paup, Gary R. Allen, Jonathan S. Cohen and David A. Shuster of Washington, DC, appear on the brief of the appellee.

Before MAGILL and LOKEN, Circuit Judges, and EISELE, Senior District Judge.

LOKEN, Circuit Judge.

This is an action by the United States under 26 U.S.C. §§ 7401 and 7403 to set aside a fraudulent conveyance and to foreclose federal tax liens on the conveyed properties. In November 1985, Kermit Bryant pleaded guilty to a criminal tax violation and promised, as a condition of probation, to "pay all taxes, penalties, and interest correctly assessed by the Internal Revenue Service." Bryant and his wife, Frances, then filed a petition...

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