Sherman R. Solaas - Page 15

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          Therefore, we hold that the alleged transfer was not constructive           
          fraud on KBI's creditors.                                                   
          Conclusion                                                                  
               For the reasons stated above, we hold that Mr. Solaas is not           
          liable as a transferee for KBI's taxes and additions thereto.  To           
          reflect the foregoing,                                                      
                                                  Decision will be entered            
                                             for petitioner.                          
































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