Larry D. & Gail Scott - Page 1

                                 T.C. Memo. 2000-369                                  

                               UNITED STATES TAX COURT                                

                        LARRY D. & GAIL SCOTT, Petitioners v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3509-99.                  Filed December 7, 2000.           

               Larry D. & Gail Scott, pro sese.                                       
               Susan Smith Canavello, for respondent.                                 

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge Lewis R. Carluzzo pursuant to section 7443A(b)(5) 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.                       

               1 Unless otherwise indicated, section references are to the            
          Internal Revenue Code in effect at the time that the petition was           
          filed in this case.  Rule references are to the Tax Court Rules             
          of Practice and Procedure.                                                  

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