H&H Trim & Upholstery Co., Inc. - Page 1


                                 T.C. Memo. 2003-9                                    

                               UNITED STATES TAX COURT                                

                  H & H TRIM & UPHOLSTERY CO., INC., Petitioner v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2482-00.                Filed January 9, 2003.              

               Dane R. Halse (an officer), for petitioner.                            
               J. Michael Melvin, for respondent.                                     

                       MEMORANDUM FINDINGS OF FACT AND 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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