Rafael Manzueta - Page 2

                           T.C. Summary Opinion 2005-185                              

                               UNITED STATES TAX COURT                                

                           RAFAEL MANZUETA, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 23394-04S.           Filed December 21, 2005.               

               Rafael Manzueta, pro se.                                               
               Nina P. Ching, for respondent.                                         

               DEAN, Special Trial Judge:  This case was heard pursuant to            
          the provisions of sections 7463 of the Internal Revenue Code in             
          effect at the time the petition was filed.  Unless otherwise                
          indicated, subsequent section references are to the Internal                
          Revenue Code as in effect for the year at issue, and all Rule               
          references are to the Tax Court Rules of Practice and Procedure.            
          The decision to be entered is not reviewable by any other court,            
          and this opinion should not be cited as authority.                          

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