Bruce A. and Kathy J. Krist - Page 1

                                 T.C. Memo. 2001-140                                  

                               UNITED STATES TAX COURT                                

                     BRUCE A. AND KATHY J. KRIST, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 22563-97.                    Filed June 15, 2001.           

               Bruce A. Krist, pro se.                                                
               Joanne B. Minsky, for respondent.                                      

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               DAWSON, Judge: This case was assigned to Special Trial Judge           
          Pajak pursuant to section 7443A(b)(4), Internal Revenue Code in             
          effect when the petition was filed, and Rules 180, 181, and 183,            
          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.                                                                

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