Norman P. Schiff - Page 2














                            T.C. Summary Opinion 2007-148                             


                               UNITED STATES TAX COURT                                


                           NORMAN P. SCHIFF, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 6781-05S, 11265-05S.  Filed August 27, 2007.               


               Norman P. Schiff, pro se.                                              
               Orsolya Kun, for respondent.                                           


               NIMS, Judge:  These cases were heard pursuant to the                   
          provisions of section 7463 of the Internal Revenue Code in effect           
          when the petitions were filed.  Pursuant to section 7463(b), the            
          decisions to be entered are not reviewable by any other court,              
          and this opinion shall not be treated as precedent for any other            
          case.  Unless otherwise indicated, all section references are to            









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