Gregory Stewart Malone and Pamela Joyce Malone - Page 1

                                        T.C. Memo. 1998-372                                             

                                     UNITED STATES TAX COURT                                            

              GREGORY STEWART MALONE AND PAMELA JOYCE MALONE, Petitioners v.                            
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                   

                  Docket No. 24609-97.                Filed October 13, 1998.                           

                  Gregory Stewart Malone and Pamela Joyce Malone, pro sese.                             
                  James F. Prothro, for respondent.                                                     

                                        MEMORANDUM OPINION                                              
                  COHEN, Chief Judge:  This case was assigned to Special Trial                          
            Judge John F. Dean pursuant to section 7443A(b)(4) and Rules 180,                           
            181, and 183.1  The Court agrees with and adopts the opinion of                             
            the Special Trial Judge, which is set forth below.                                          

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

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