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UNITED STATES v. WILLIS

Civ. No. 81-511-C.

565 F.Supp. 1186 (1983)

UNITED STATES of America, and Russell G. Talbot, Special Agent of the Internal Revenue Service, Petitioners, v. Ned WILLIS, Respondent, and William M. Siglin and Virginia J. Siglin, Intervenors.

United States District Court, S.D. Iowa, C.D.

May 13, 1983.

Attorney(s) appearing for the Case

Marshall I. Whitley, Tax Div., Dept. of Justice, Washington, D.C., and Richard Turner, Des Moines, Iowa, Helen L. Duncan, Trial Atty., Tax Div., Dept. of Justice, Washington, D.C., for petitioners.

Bruce B. Graves, Jill Thompson Hansen, Harold N. Schneebeck, Jr., Des Moines, Iowa, for movant intervenors W. & V. Siglin.

William Sidney Smith, Smith, Schneider & Stiles, P.C., Des Moines, Iowa, for respondent Ned Willis.

Thomas W. Carpenter, Chairman, Tax Committee, Des Moines, Iowa, for amicus curiae.

RULING AND ORDER

STUART, Chief Judge.

The Court has before it the parties' objections to Magistrate Longstaff's July 26, 1982 Report and Recommendation (hereinafter Report). A copy of the Report is hereto attached as Appendix A. The procedural history of this action is set forth at the outset of the Report and will not be repeated herein.

The parties have not objected to the analysis and conclusions contained in Divisions I and II of the Report....

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