Lester L. and Susan P. Samford - Page 1

                                 T.C. Memo. 2000-266                                  

                               UNITED STATES TAX COURT                                

                   LESTER L. AND SUSAN P. SAMFORD, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 13597-91.                  Filed August 24, 2000.           

               Thomas E. Redding, for petitioners.                                    
               Robert E. Marum, for respondent.                                       

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               POWELL, Special Trial Judge: This case is before the Court             
          on petitioners’ motion to dismiss for lack of jurisdiction.                 
          Petitioners are part of a group of investors in a partnership,              
          Summer Lovers Associates (SLA).  Six other partners, who have               
          petitions pending in this Court, have also filed motions to                 
          dismiss.  In those six cases the petitioners have agreed that               
          this case will serve as the test case as to the motions to                  
          dismiss.  This case was submitted fully stipulated under Rule               

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