Claire C. Meade, Petitioner and James W. Meade, Intervenor - Page 1

                                 T.C. Memo. 2006-209                                  

                               UNITED STATES TAX COURT                                

            CLAIRE C. MEADE, Petitioner AND JAMES W. MEADE, Intervenor v.             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 8357-04.           Filed September 27, 2006.                

               Claire C. Meade, pro se.                                               
               James W. Meade, pro se.                                                
               Lauren B. Epstein, for respondent.                                     

                                 MEMORANDUM OPINION                                   

               KROUPA, Judge:  This case was assigned to and trial was                
          conducted by Chief Special Trial Judge Peter J. Panuthos pursuant           
          to section 7443A(b)(6)1 and Rules 180 and 183.  His recommended             

               1  All Rule references are to the Tax Court Rules of                   

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