William M. Donovan - Page 1

                                 T.C. Memo. 2000-220                                  

                               UNITED STATES TAX COURT                                

                          WILLIAM M. DONOVAN, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket Nos. 18855-97, 23139-97.         Filed July 21, 2000.           

               Alyce C. Halchak, for petitioner.                                      
               Julia A. Cannarozzi, for respondent.                                   
                                 MEMORANDUM OPINION                                   
               DAWSON, Judge:  These cases were assigned to Special Trial             
          Judge Lewis R. Carluzzo pursuant to section 7443A(b)(4) and Rules           
          180, 181, and 183.1  The Court agrees with and adopts the opinion           
          of the Special Trial Judge, which is set forth below.                       

          1Unless otherwise indicated, section references are to the                  
          Internal Revenue Code in effect at the time that the petitions              
          were filed in these cases.  Rule references are to the Tax Court            
          Rules of Practice and Procedure.                                            

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