Court of Appeals for the Eighth Circuit October 5, 1995, 94-3864 (United States v. Ervin J. Klaphake)

WOLLMAN, Circuit Judge.

Ervin J. Klaphake appeals his conviction of two counts of tax evasion in violation of 26 U.S.C. § 7201. We affirm.

I.

Klaphake owned and operated a 500-acre farm in Melrose, Minnesota. In 1983, Norbert Stelton and James Noske, both realtors, and Joan Noske, an accountant and tax return preparer, spoke with Klaphake concerning the formation of business trusts.