BHC Trust - Page 1

                                       T.C. Memo. 2000-274                                             

                                     UNITED STATES TAX COURT                                           

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

                  Docket No. 16062-99.                  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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