Milward Corporation - Page 1

                                 T.C. Memo. 1996-391                                  

                               UNITED STATES TAX COURT                                

                         MILWARD CORPORATION, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

          Docket No. 16005-93.                  Filed August 21, 1996.                

          Meryl Silver, 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)(4) and Rules 180, 181, and 183.1  The Court agrees with            

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

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