Marian and Maria Juskuv - Page 1

                                 T.C. Memo. 1999-144                                  

                               UNITED STATES TAX COURT                                

                       MARIAN AND MARIA JUSKUV, Petitioners v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10725-97.             Filed April 30, 1999.                 

               Marian Juskuv, pro se.                                                 
               Louise R. Forbes, for respondent.                                      

                                 MEMORANDUM OPINION                                   
          DAWSON, Judge:  This case was assigned to Special Trial                     
          Judge Stanley J. Goldberg, 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 in             
          effect for the year in issue, and all Rule references are to the            
          Tax Court Rules of Practice and Procedure.                                  

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