No. 94-3864.

64 F.3d 435 (1995)

UNITED STATES of America, Appellee, v. Ervin J. KLAPHAKE, Appellant.

United States Court of Appeals, Eighth Circuit.

Decided August 30, 1995.

Rehearing Denied October 5, 1995.

Attorney(s) appearing for the Case

Steven A. Peterson, Bloomington, MN, argued (Thomas L. Iliff, on the brief), for appellant.

Wade W. Parrish, U.S. Dept. of Justice, Washington, DC, argued (Robert E. Lindsay, Alan Hechtkopf and Loretta C. Argrett, on the brief), for appellee.

Before WOLLMAN and MORRIS SHEPPARD ARNOLD, Circuit Judges, and BOGUE, Senior District Judge.

WOLLMAN, Circuit Judge.

Ervin J. Klaphake appeals his conviction of two counts of tax evasion in violation of 26 U.S.C. § 7201. We affirm.


Klaphake owned and operated a 500-acre farm in Melrose, Minnesota. In 1983, Norbert Stelton and James Noske, both realtors, and Joan Noske, an accountant and tax return preparer, spoke with Klaphake concerning the formation of business trusts. Shortly thereafter, Klaphake transferred his farm real estate...

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