Kolotolu V. and Seini Liti - Page 1

                                 T.C. Memo. 2003-23                                   

                               UNITED STATES TAX COURT                                

                     KOLOTOLU V. AND SEINI LITI, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 2404-00.                Filed January 27, 2003.             

               A. Lavar Taylor, for petitioners.                                      
               Louis Jack, for respondent.                                            

                                 MEMORANDUM OPINION                                   

               FOLEY, Judge:  This matter is before the Court on remand               
          from the Court of Appeals for the Ninth Circuit for further                 
          consideration consistent with its opinion in Liti v.                        
          Commissioner, 289 F.3d 1103 (9th Cir. 2002) (vacating and                   
          remanding this Court’s order and decision, dated May 24, 2001,              
          denying petitioners’ request for litigation and administrative              

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