Rancho Residential Services Trust, Robert Hogue, Trustee - Page 1















                                  T.C. Memo. 2003-57                                   


                               UNITED STATES TAX COURT                                 


              RANCHO RESIDENTIAL SERVICES TRUST, ROBERT HOGUE, TRUSTEE,                
             Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent                


               Docket No. 2211-02.              Filed March 3, 2003.                   

               Robert Hogue, pro se.                                                   
               Jeremy L. McPherson, for respondent.                                    

                                  MEMORANDUM OPINION                                   

               DAWSON, Judge:  This case was assigned to Special Trial                 
          Judge Robert N. Armen, Jr., pursuant to the provisions of 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, all section references are to            
          the Internal Revenue Code, as amended, and all Rule references               
          are to the Tax Court Rules of Practice and Procedure.                        




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