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THOBURN v. COMMISSIONER

Docket Nos. 39546-87-39554-87.

95 T.C. 132 (1990)

ROBERT THOBURN, ET AL., PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 13, 1990.

Attorney(s) appearing for the Case

Samuel C. Ullman and John Tenenholtz, for the petitioners.

Roslyn D. Grand and David Albert Mustone, for the respondent.

OPINION

WELLS, Judge:

The instant case is before the Court on two motions filed by petitioners. The first motion is entitled motion to dismiss for lack of subject matter jurisdiction, or in the alternative, limit the amount of respondent's determination. The second motion is entitled motion to dismiss for lack of subject matter jurisdiction.2

The instant case concerns petitioners' liability for section 4975

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