BHC Trust - Page 7




                                                - 7 -                                                  

            T.C. Memo. 2000-275; Malvern Hills Trust v. Commissioner, T.C.                             
            Memo. 2000-273; PM Trust v. Commissioner, T.C. Memo. 2000-272;8                            
            cf. Renaissance Enters. Trust v. Commissioner, supra.                                      
                  To reflect the foregoing,                                                            
                                                            An appropriate order of                    
                                                      dismissal for lack of                            
                                                      jurisdiction will be entered.                    

























            8 We have decided the same issue adverse to the trusts in                                  
            the cases of Al Trust, Malvern Hills Trust, PM Trust, and YMO                              
            Trust.  Mr. Jablonski also petitioned the Court on behalf of each                          
            of those trusts, and the records in those cases were virtually                             
            identical to the record at hand.                                                           





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