United States Court of Appeals FOR THE EIGHTH CIRCUIT ___________

No. 03-3389 ___________

Dale L. Oyer, Transferee, * * Appellant, * * v. * * Commissioner of Internal * Revenue Service, * * Appellee. *

___________ Appeals from the United States Tax Court. No. 03-3390 ___________ [UNPUBLISHED]

Acme Leasing Trust, Transferee, * * Appellant, * * v. * * Commissioner of Internal * Revenue Service, * * Appellee. * ___________

No. 03-3391 ___________

ABC Seamless Trust, Transferee, * * Appellant, * * v. * * Commissioner of Internal * Revenue Service, * * Appellee. *

___________

No. 03-3392 ___________

Shirley J. Oyer, Transferee, * * Appellant, * * v. * * Commissioner of Internal * Revenue Service, * * Appellee. *

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Submitted: April 16, 2004

Filed: May 20, 2004 ___________

Before MORRIS SHEPPARD ARNOLD, MAGILL, and MURPHY, Circuit Judges. ___________

PER CURIAM.

This is an appeal from the Tax Court's order granting summary judgment in favor of the Internal Revenue Service in taxpayers' suit challenging the IRS's determination that they were liable as transferees for taxes in the amount of approximately $90,000. The Tax Court held, inter alia, that the doctrine of res judicata barred taxpayers from contesting the amount owed because the court had previously entered stipulated decisions against taxpayers that determined the taxes that are the subject of the dispute here.

We have carefully examined the record and conclude that the Tax Court correctly applied the doctrine of res judicata in this case. We therefore affirm on the basis of its well-reasoned decision. See 8th Cir. R. 47B. ______________________________

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