Jean A. Stanko - Page 13

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          voided the transfers.  Id. at 17.  On May 23, 1991, the Court               
          entered its judgment, voiding the following transfers (among                
          others) as fraudulent conveyances to petitioner:  (a) The                   
          September 19, 1985, conveyance of Stanko's interest in lots 1 and           
          2, block 5, Ditch North Addition, Scottsbluff; (b) the October 4,           
          1985, conveyance by Butch's Cattle Co. of lots 10, 11, and 12,              
          block 10 of the L.G. Gill subdivision in Jackson, Wyoming; and              
          (c) the October 7, 1985, conveyance by the School of Gymnastics,            
          Inc., of lots 8, 9, and 10, block 2, City Addition, Scotts Bluff            
          County.                                                                     
               Petitioner appealed the Giove case.  In Giove v. Stanko, 977           
          F.2d 413 (8th Cir. 1992), the U.S. Court of Appeals for the                 
          Eighth Circuit affirmed the judgment of the U.S. District Court             
          for the District of Nebraska.  The judgment in Giove v. Stanko,             
          supra, is final.                                                            
          K.   Notice of Transferee Liability                                         
               Respondent issued a notice of transferee liability to                  
          petitioner on August 7, 1991.  Stanko Packing had been dissolved            
          and no longer existed at that time.                                         
          L.   Stanko's Tax Court Case                                                
               Stanko filed a petition in this Court on November 4, 1991.             
          Stanko v. Commissioner, docket No. 25257-91.  In the petition,              
          Stanko disputed the Commissioner's determination that he was                
          liable as a transferee of the assets of Stanko Packing for the              
          corporation's income tax liability for the taxable year that                




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