                          116 T.C. No. 24



                   UNITED STATES TAX COURT



        GARY D. AND LINDY H. COMBRINK, Petitioners v.
         COMMISSIONER OF INTERNAL REVENUE, Respondent



   Docket No. 13580-99.                     Filed May 15, 2001.


   This opinion was withdrawn by order dated

August 14, 2001.
