Harris Rabinovich - Page 2

                            T.C. Summary Opinion 2004-15                              


                               UNITED STATES TAX COURT                                


                          HARRIS RABINOVICH, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 14998-02S.            Filed February 11, 2004.              

               Harris Rabinovich, pro se.                                             
               Russell K. Stewart, for respondent.                                    


               PANUTHOS, Chief Special Trial Judge:  This case was heard              
          pursuant to the provisions of sections 6330(d) and 7463.1  The              
          decision to be entered is not reviewable by any other court, and            
          this opinion should not be cited as authority.                              




               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code, as amended, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure.                       




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