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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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