Neil Rabinowitz - Page 2

                            T.C. Summary Opinion 2006-186                             

                               UNITED STATES TAX COURT                                

                           NEIL RABINOWITZ, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11264-05S.         Filed December 11, 2006.                 

               Neil Rabinowitz, pro se.                                               
               James H. Harris, Jr., for respondent.                                  

               POWELL, Special Trial Judge:  This case was heard pursuant             
          to the provisions of section 74631 of the Internal Revenue Code             
          in effect at the time 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, subsequent section references              
          are to the Internal Revenue Code.                                           

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