Service Engineering Trust - Page 1
















                                 T.C. Memo. 2001-181                                  


                               UNITED STATES TAX COURT                                


                       SERVICE ENGINEERING TRUST, Petitioner v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
                   CHARLES W. AND LORAINE LEDFORD, Petitioners v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket Nos. 2021-00L, 2658-00L.    Filed July 20, 2001.                

               Joyce Griggs, for petitioners.                                         
               Ross M. Greenberg, for respondent.                                     


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        


               FOLEY, Judge:  The issue in this case is whether respondent            
          has met the requirements of section 6320.  All section references           
          are to the Internal Revenue Code as amended.                                









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