Elliot G. Steinberg - Page 1

















                                 T.C. Memo. 1999-311                                  


                               UNITED STATES TAX COURT                                


                         ELLIOT G. STEINBERG, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 44873-85.               Filed September 21, 1999.           

               Walter F. Spath III, for petitioner.                                   
               John J. Comeau, for respondent.                                        


                                 MEMORANDUM OPINION                                   
               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge D. Irvin Couvillion pursuant to 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 Rule references are to the Tax Court Rules of                 
          Practice and Procedure.                                                     




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