Laurence L. Grabowski - Page 2















                            T.C. Summary Opinion 2007-74                              


                               UNITED STATES TAX COURT                                


                        LAURENCE L. GRABOWSKI, Petitioner v.                          
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 13861-05S.             Filed May 17, 2007.                  


               Laura Perrin (specially recognized), for petitioner.                   
               Steven W. LaBounty, for respondent.                                    


               FOLEY, Judge:  This case was heard pursuant to section 74631           
          of the Internal Revenue Code.  Pursuant to the provisions of                
          section 7463(b), the decision to be entered is not reviewable by            
          any other court, and this opinion shall not be treated as                   
          precedent for any other case.  The issues for decision are                  


               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code in effect for the year in issue.                  






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