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















                                   T.C. Memo. 2003-56                                    


                                UNITED STATES TAX COURT                                  


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


               Docket No. 2210-02.             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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