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U.S. v. FIRST DAKOTA NAT. BANK

No. Civil 93-4162.

963 F.Supp. 855 (1997)

UNITED STATES of America, Plaintiff, v. FIRST DAKOTA NATIONAL BANK, Defendant.

United States District Court, D. South Dakota, Southern Division.

January 6, 1997.

Attorney(s) appearing for the Case

Charles P. Hurley, U.S. Dept. of Justice, Washington, DC, for plaintiff.

Steven M. Johnson, Johnson, Heidepriem, Miner & Marlow, Sioux Falls, SD, for defendant.

MEMORANDUM OPINION GRANTING JUDGMENT AS A MATTER OF LAW

KORNMANN, District Judge.

INTRODUCTION

The plaintiff filed this action seeking to collect an unpaid tax liability owed by American State Bank ("American") from the 1981 tax year. First Dakota National Bank ("First Dakota") acquired American in 1988, agreeing to assume all liabilities of American, except for shareholder liabilities. At the time of the purchase, all concerned knew American's...

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