Barry and Debra Bulakites - Page 1

                                 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           

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