Ronald Thomas - Page 1

                                 T.C. Memo. 1998-438                                  

                               UNITED STATES TAX COURT                                

          RONALD THOMAS, Petitioner v.                                                
          COMMISSIONER OF INTERNAL REVENUE, Respondent                                

          Docket No. 3595-98.                 Filed December 15, 1998.                

          Joseph L. Gibson, Jr., for petitioner.                                      
               Stuart Spielman and Helen F. Rogers, for respondent.                   

                                 MEMORANDUM OPINION                                   
               DAWSON, Judge:  This case was assigned to Chief Special                
          Trial Judge Peter J. Panuthos 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,              
          which is set forth below.                                                   

          1  All section references are to the Internal Revenue Code                  
          as amended.  All Rule references are to the Tax Court Rules of              
          Practice and Procedure.                                                     

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