Frank Harrell - Page 2

                            T.C. Summary Opinion 2006-141                             


                               UNITED STATES TAX COURT                                


                            FRANK HARRELL, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 19193-05S.           Filed September 13, 2006.              


               Frank Harrell, pro se.                                                 
               Carrie L. Kleinjan, for respondent.                                    


               RUWE, Judge:  This case was heard pursuant to section 74631            
          in effect when the petition was filed.  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, section references are to the            
          Internal Revenue Code in effect for the years in issue.  Rule               
          references are to the Tax Court Rules of Practice and Procedure.            




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