                     T.C. Memo. 2005-56



                   UNITED STATES TAX COURT



  PK VENTURES, INC. AND SUBSIDIARIES, ET AL., Petitioners v.
         COMMISSIONER OF INTERNAL REVENUE, Respondent



   Docket Nos. 5836-99, 6395-99,     Filed March 28, 2005.
               10154-99.



   This opinion was withdrawn by order dated

March 7, 2006.
