Court of Appeals for the Eighth Circuit April 20, 2000, 99-1297 (Jean A. Stanko v. Commissioner of Internal Revenue)

LOKEN, Circuit Judge.

This case raises novel and difficult questions concerning transferee liability under the Internal Revenue Code. The transferee, Jean Stanko, appeals the Tax Court’s determination that she is liable for $3,442,-874 in unpaid taxes owed by Stanko Packing, Inc.