Ronald McLean Eastern Video - Page 1

                                 T.C. Memo. 2003-13                                   

                               UNITED STATES TAX COURT                                

                     RONALD McLEAN EASTERN VIDEO, Petitioner v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 7721-01.               Filed January 14, 2003.              

               Ronald McLean, for petitioner.                                         
               Michael K. Park, for respondent.                                       

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               DAWSON, Judge:  This case was assigned to Special Trial                
          Judge John F. Dean 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 in effect for the year and quarters at                
          issue, and Rule references are to the Tax Court Rules of Practice           
          and Procedure.                                                              

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