Joseph Green and Fe Green - Page 1

                                         T.C. Memo. 1995-466                                               

                                       UNITED STATES TAX COURT                                             

                           JOSEPH GREEN AND FE GREEN, Petitioners v.                                       
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                      

                  Docket No. 18985-94.                        Filed October 2, 1995.                       

                  Joseph Green, for petitioners.                                                           
                  Steven W. Ianacone, for respondent.                                                      

                                          MEMORANDUM OPINION                                               
                  DAWSON, Judge:  This case was assigned to Chief Special                                  
            Trial Judge Peter J. Panuthos, pursuant to the provisions of                                   
            section 7443(b)(4) 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 in effect for the taxable year in                                 
            issue.  All Rule references are to the Tax Court Rules of                                      
            Practice and Procedure.                                                                        

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