Meserve Drilling Partners, Regional Resources, Inc., F.K.A. R&R Energy, Inc., Tax Matters Partner - Page 1

                                 T.C. Memo. 1996-72                                   


                               UNITED STATES TAX COURT                                


          MESERVE DRILLING PARTNERS, REGIONAL RESOURCES, INC., F.K.A. R & R           
                  ENERGY, INC., TAX MATTERS PARTNER, Petitioner v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
          COLUMBIA ENERGY FUND 1982, REGIONAL RESOURCES, INC., F.K.A. R & R           
                  ENERGY, INC., TAX MATTERS PARTNER, Petitioner v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket Nos. 19262-86, 19904-86.    Filed February 21, 1996.            

               Robert B. Martin, Jr., for petitioner.                                 

               Jack H. Klinghoffer, for respondent.                                   

                                 MEMORANDUM OPINION                                   
               DAWSON, Judge:  These cases were assigned to Special Trial             
          Judge Larry L. Nameroff pursuant to section 7443A(b)(4) of the              
          Code and Rules 180, 181, and 183.1  The Court agrees with and               

          1         All section references are to the Internal Revenue Code           
          in effect for the years in issue.  All Rule references are to the           
          Tax Court Rules of Practice and Procedure.                                  




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