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GOULARD v. COMMISSIONER

Docket Nos. 25665-87, 25666-87, 25667-87, 25668-87.

60 T.C.M. 567 (1990)

T.C. Memo. 1990-448

Alexander Goulard, Jr., et al. v. Commissioner.

United States Tax Court.

Filed August 21, 1990.

Attorney(s) appearing for the Case

Thomas G. Christmann and Walter M. Tovkach, 527 E. University Ave., Gainesville, Fla., for the petitioners. Roslyn D. Grand and David Albert Mustone, for the respondent.

Memorandum 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 Jurisdiction," and the second motion is entitled "Second Motion to Dismiss for Lack of Subject Matter Jurisdiction."

The instant case concerns petitioners' liability for section 49752 excise taxes because of loans made to them by a qualified pension plan...

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