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STANKO v. C.I.R.

No. 99-1297.

209 F.3d 1082 (2000)

Jean A. STANKO, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Filed April 20, 2000.

Attorney(s) appearing for the Case

Robert B. Creager, Lincoln, NE, argued, for appellant.

Anthony T. Sheehan, Washington, D.C., argued (Richard Farber, Washington, D.C., on the brief), for appellee.

Before RICHARD S. ARNOLD and LOKEN, Circuit Judges, and MELLOY, District Judge.

LOKEN, Circuit Judge.

This case raises novel and difficult questions concerning transferee liability under the Internal Revenue Code. The transferee, Jean Stanko, appeals the Tax Court's determination that she is liable for $3,442,874 in unpaid taxes owed by Stanko Packing, Inc. ("Stanko Packing"), because she is the successor transferee of an installment note fraudulently conveyed by Stanko Packing to its sole shareholder, Jean's former spouse, Rudy Stanko. We agree...

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