Rehearing and Suggestion for Rehearing En Banc Denied October 20, 1995.
COFFEY, Circuit Judge.
The father of John Vincent and Neal Stuart Dubisky, Michael, established trust accounts for his two sons. The IRS is trying to collect over $4 million in taxes from Michael, and levied on the accounts, which contain over $200,000 each, claiming that the accounts belonged to the children in name only, and were really the property of Michael. The children seek to contest...
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