                      T.C. Memo. 2001-35



                   UNITED STATES TAX COURT



     GREG McINTOSH AND SHEILA R. McINTOSH, Petitioners v.
         COMMISSIONER OF INTERNAL REVENUE, Respondent



   Docket No. 15076-99.                Filed February 13, 2001.


   This opinion was withdrawn by order dated March

13, 2001.
