Jeffrey C. and Kelly O. Stone - Page 1

                                 T.C. Memo. 1998-437                                  

                               UNITED STATES TAX COURT                                

                    JEFFREY C. AND KELLY O. STONE, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3812-97.             Filed December 14, 1998                

               Jeffrey C. and Kelly O. Stone, pro se.                                 
               Joan S. Dennett, for respondent.                                       

                                 MEMORANDUM OPINION                                   

               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge Carleton D. Powell pursuant to the provisions of section              
          7443A(b)(4) and Rules 180, 181, and 183.1  The Court agrees with            
          and adopts the opinion of the Special Trial Judge that is set               
          forth below.                                                                

               1  Unless otherwise indicated, section references are to the           
          Internal Revenue Code in effect for the year in issue, and Rule             
          references are to the Tax Court Rules of Practice and Procedure.            

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