                      T.C. Memo. 2010-27



                    UNITED STATES TAX COURT



         JAMES L. AND BARBARA B. PURDY, Petitioners v.
          COMMISSIONER OF INTERNAL REVENUE, Respondent




    Docket No. 26679-08.             Filed February 17, 2010.



    This opinion was withdrawn by order dated March 2,

2010.
