Michael M. Dew - Page 1

                                 T.C. Memo. 1999-34                                   

                               UNITED STATES TAX COURT                                

          MICHAEL M. DEW, Petitioner v.                                               
          COMMISSIONER OF INTERNAL REVENUE, Respondent                                

          Docket No. 8801-98.            Filed February 3, 1999.                      

          Michael M. Dew, pro se.                                                     
          Deborah Swann and Elizabeth S. Henn, for respondent.                        

                                 MEMORANDUM OPINION                                   

               CHABOT, 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  Unless otherwise indicated, 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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