Dereco, Inc. - Page 1

                                 T.C. Memo. 2000-279                                  

                               UNITED STATES TAX COURT                                

                             DERECO, INC., Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 893-98.                    Filed August 30, 2000.           

               Herbert W. Linder, for respondent.                                     

                                 MEMORANDUM OPINION                                   

               PARR, Judge:  This case is before us on respondent's motion            
          to dismiss for lack of prosecution.  Because of the relief sought           
          therein, we treat the motion as a motion to dismiss for lack of             
          prosecution as to the deficiencies and a motion for default as to           
          the additions to tax for fraud.                                             
               Respondent determined the following deficiencies in                    

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