United States Eighth Circuit

The assignment of annuity contracts as collateral for a loan was properly treated as a taxable event; taxpayers cannot collaterally attack the assignment when they have neglected to do so directly.

Appellate Information

• Decided 05/03/2004
• Published 05/03/2004

Judges

• HEANEY, Circuit Judge., Before MURPHY, HEANEY, and SMITH, Circuit Judges.

Court

• United States Eighth Circuit

Counsel

• For Appellant:
  
• Jon J. Jensen, argued, Grand Forks, North Dakota, for appellant.


• For Appellees:
  
• Robert J. Branman, argued, Washington, D.C. (Eileen J. O'Connor, David English Carmack, and Drew H. Wrigley on the brief), for appellee.