Clifford E. Barbour, Jr. and Dorothy D. Barbour - Page 1

                                 T.C. Memo. 2000-256                                   

                               UNITED STATES TAX COURT                                 

           CLIFFORD E. BARBOUR, JR. AND DOROTHY D. BARBOUR, Petitioners v.             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                       

               Docket No. 3312-97.                   Filed August 14, 2000.            

               Brian C. Quist, for petitioner Clifford E. Barbour.                     
          Rebecca D. Harris and John R. Keenan, for respondent.                        

                                  MEMORANDUM OPINION                                   

               DAWSON, Judge:  This case was assigned to Special Trial                 
          Judge Robert N. Armen, Jr., pursuant to Rules 180, 181, and 183.1            

               1  All Rule references are to the Tax Court Rules of                    
          Practice and Procedure.  Unless otherwise indicated, all section             
          references are to the Internal Revenue Code in effect for the                
          taxable years in issue.  However, all references to sec. 7430 are            
          to such section in effect when the petition was filed (Feb. 20,              

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