Tim R. Casanova and San Juanita Villareal - Page 1

                                 T.C. Memo. 1999-28                                   

                               UNITED STATES TAX COURT                                

          TIM R. CASANOVA AND SAN JUANITA VILLAREAL, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

          Docket No. 10605-98.                 Filed February 1, 1999.                

               Tim R. Casanova and San Juanita Villareal, pro sese.                   
               Melinda G. Williams and James G. Macdonald, for respondent.            

                                 MEMORANDUM OPINION                                   
               COHEN, Chief Judge:  This case was assigned to Special Trial           
          Judge Robert N. Armen, Jr., 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, and all Rule references are to the Tax Court Rules of           
          Practice and Procedure.                                                     

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