Lawrence S. and Myrna Ahmaogak - Page 1

        T.C. Memo. 2003-238                                                           

                               UNITED STATES TAX COURT                                

              LAWRENCE S. AHMAOGAK AND MYRNA AHMAOGAK, Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 10850-01.          Filed August 11, 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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