Michael London - Page 67

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             additions to tax for 1983 and 1985 under former section                  
             6013(e).  Following passage of section 6015 by the Internal              
             Revenue Service Restructuring and Reform Act of 1998, Pub.               
             L. 105-206, sec. 3201(a), 112 Stat. 685, 734, the Court is               
             deferring consideration of this issue until the parties                  
             have been given an opportunity to provide the Court with                 
             their positions concerning the effect of the new law.                    


             To reflect the foregoing,                                                

                                             An appropriate order will                
                                        be issued.                                    

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