AL Trust - Page 1

                                 T.C. Memo. 2000-276                                  

                               UNITED STATES TAX COURT                                

                              AL TRUST, Petitioner v.                                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 16059-99.                  Filed August 29, 2000.           

               Cheryl R. Frank and Gerald W. Kelly, for petitioner.1                  
               Mary Ann Waters, for respondent.                                       

                                 MEMORANDUM OPINION                                   

               LARO, Judge:  Respondent moves the Court to dismiss this               
          case for lack of jurisdiction, arguing that the petition was not            
          filed with the Court by a proper party as required by Rule                  

          1 Ms. Frank and Mr. Kelly entered their appearance on July                  
          17, 2000.  Petitioner’s petition was filed with the Court by                
          petitioner’s managing director, David Jablonski (Mr. Jablonski).            

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