Your search Notice: Eighth Circuit Rule 28a(k) Governs Citation of Unpublished Opinions and Provides That They Are Not Precedent and Generally Should Not Be Cited Unless Relevant to Establishing the Doctrines of Res Judicata, Collateral Estoppel, the Law of the Case, or if the Opinion Has Persuasive Value on a Material Issue and No Published Opinion Would Serve As Well.charles Hefti; Marion Hefti, Appellants, v. Kevin Mcgrath, Revenue Agent, Individually; Thomas Wettig,appeals Officer, Individually; James Jewik, Irs Supervisor,individually; Frank Braffman, Chief Appeals Officer,individually; Edward Busekrus, Associate Chief of Appeals,individually; James Kutten, Irs Senior Attorney,individually, Appellees did not match any document.