Dale I. Dirkes - Page 1

                                 T.C. Memo. 2001-98                                   

                               UNITED STATES TAX COURT                                

                            DALE I. DIRKES, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11924-98.                   Filed April 24, 2001.           

               Dale I. Dirkes, pro se.                                                
               Frederick W. Krieg, for respondent.                                    

                                 MEMORANDUM OPINION                                   
               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge Daniel J. Dinan pursuant to the provisions of section                 
          7443A(b)(5).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 for the year in issue.  Rule            
          references are to the Tax Court Rules of Practice and Procedure.            

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