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U.S. v. SNYDER

No. 3:01-CV796(PCD).

233 F.Supp.2d 293 (2002)

UNITED STATES of America, Plaintiff, v. Susan SNYDER, et al., Defendants.

United States District Court, D. Connecticut.

August 14, 2002.

Attorney(s) appearing for the Case

Christine L. Sciarrino, U.S. Attorney's Office, New Haven, CT, John V. Cardone, John A. Lindquist, Jennifer G. Cohen, U.S. Department of Justice Tax Division, Washington, DC, for Plaintiff.

Edwin L. Doernberger, Saxe, Doernberger & Vita, PC, Hamden, CT, David L. Gussak, Reiner, Reiner & Bendett, Farmington, CT, for Defendants.

RULING ON UNITED STATES'S MOTION FOR SUMMARY JUDGMENT

DORSEY, Senior District Judge.

Plaintiff, the United States of America, moves for summary judgment. Its motion is denied.

I. JURISDICTION

Subject matter jurisdiction is pursuant to 28 U.S.C. §§ 1340, 1345 and 22 U.S.C. §§ 7402, 7403.

II. BACKGROUND

The following facts are undisputed. During 1989, 1990, and 1991, Russell and Stelle Mahler ...

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