Orlander Robinson - Page 1

                                 T.C. Memo. 2000-146                                  

                               UNITED STATES TAX COURT                                

                          ORLANDER ROBINSON, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10505-99.                   Filed April 24, 2000.           

               J. Donald Hughes, for petitioner.                                      
               John F. Driscoll, for respondent.                                      

                                 MEMORANDUM OPINION                                   
          DAWSON, Judge:  This case was assigned to Special Trial                     
          Judge John J. Pajak pursuant to Rules 180, 181, and 183.  All               
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.  The Court agrees with and adopts the opinion of the             
          Special Trial Judge, which is set forth below.                              
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               PAJAK, Special Trial Judge:  This case is before the Court             

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