Fennel Trust - Page 1














                                 T.C. Memo. 2001-316                                  


                               UNITED STATES TAX COURT                                


                             FENNEL TRUST, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 10710-00.                Filed December 20, 2001.           

               Sam D. Scholar, for petitioner.                                        
               Mary Ann Waters, for respondent.                                       


                                 MEMORANDUM OPINION                                   

               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge Robert N. Armen, Jr., pursuant to the provisions of section           
          7443A(b)(5) and Rules 180, 181, and 183.1  The Court agrees with            
          and adopts the opinion of the Special Trial Judge, which is set             
          forth below.                                                                


               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code, as amended, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure.                       




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