T.C. Memo. 1998-256                                  
                               UNITED STATES TAX COURT                                
               BARRY AND DEBRA BULAKITES, Petitioners v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
               Docket No. 1269-98.                     Filed July 13, 1998.           
               Carolyn J. Jackson, for petitioners.                                   
               Robert E. Marum and Richard Fultz, 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,                 
          as amended, and all Rule references are to the Tax Court Rules of           
                                                             (continued...)           
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