Jacqueline and Theodore Major Green - Page 1

                                 T.C. Memo. 2006-39                                   


                               UNITED STATES TAX COURT                                


                 JACQUELINE AND THEODORE MAJOR GREEN, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
                 THEODORE MAJOR AND JACQUELINE GREEN, Petitioners v.                  
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 2475-04, 4970-05.      Filed March 9, 2006.                

               Jacqueline and Theodore Major Green, pro sese.                         
               Richard J. Hasserbrock, for respondent.                                


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               FOLEY, Judge:  The issues for decision are whether                     
          petitioners are entitled to exclude from income Social Security             
          benefits and deduct net operating loss (NOL) carryforwards                  
          relating to their 2000 and 2001 returns.                                    







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