                     T.C. Memo. 2006-266



                   UNITED STATES TAX COURT



      CURR-SPEC PARTNERS, LP, CURR-SPEC MANAGERS, LLC,
              TAX MATTERS PARTNER, Petitioner v.
         COMMISSIONER OF INTERNAL REVENUE, Respondent



   Docket No. 1350-05.               Filed December 14, 2006.



   This opinion was withdrawn by order dated

January 3, 2007.
