William and Arlene G. Kingston - Page 1

                                 T.C. Memo. 1998-119                                  

                               UNITED STATES TAX COURT                                

                   WILLIAM AND ARLENE G. KINGSTON, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

          Docket No. 15409-95.             Filed March 25, 1998.                      

          William and Arlene G. Kingston, pro se.                                     
          Elizabeth Flores, for respondent.                                           

                                 MEMORANDUM OPINION                                   

          WELLS, Judge:  This case was assigned to Special Trial Judge                
          D. Irvin Couvillion pursuant to section 7443A(b)(4)1 and Rules              
          180, 181, and 183.  The Court agrees with and adopts the opinion            
          of the Special Trial Judge, which is set forth below.                       

          1     Unless otherwise indicated, section references are to the             
          Internal Revenue Code.  All Rule references are to the Tax Court            
          Rules of Practice and Procedure.                                            

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