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U.S. v. JEPSEN

No. 00-2812.

268 F.3d 582 (2001)

UNITED STATES of America, Plaintiff-Appellee, v. Jack JEPSEN; Kris Jepsen; Karen Jepsen Makutenas, Defendants-Appellants.

United States Court of Appeals, Eighth Circuit.

Filed: October 10, 2001.

Attorney(s) appearing for the Case

David G. Bercaw (argued), Fayetteville, AR, for Defendants-Appellants.

Thomas J. Sawyer (argued), U.S. Dept. of Justice, Tax Div., Washington, DC (Thomas J. Clark, U.S. Dept. Justice, Tax Div., Paul M. Junghans, Acting Asst. Atty. Gen., on the brief, P.K. Holmes, of counsel), for Plaintiff-Appellee.

Before WOLLMAN, Chief Judge, LOKEN, Circuit Judge, and BOGUE, District Judge.

LOKEN, Circuit Judge.

In August 1989, Illinois resident Jack Jepsen conveyed the family's Arkansas vacation home to his children, Kris and Karen. In exchange, Jepsen received a $10,000 down-payment check from each child and an interest-bearing promissory note in the amount of $95,000 secured by a mortgage on the property. In April 1994, the United States assessed a $214,263 tax penalty against Jepsen for failure to pay employment taxes owed by his company, Jepsen...

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