George N. and Maggie Ahmaogak - Page 1

                                 T.C. Memo. 2003-220                                  

                               UNITED STATES TAX COURT                                

               GEORGE N. AHMAOGAK AND MAGGIE AHMAOGAK, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10849-01.            Filed July 23, 2003.                   

               Mason D. Morisset, for petitioners.                                    
               Lisa M. Oshiro, for respondent.                                        

                                 MEMORANDUM 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 of 1986, as amended.  Rule references are             
          to the Tax Court Rules of Practice and Procedure.                           

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