T.C. Summary Opinion 2006-110
UNITED STATES TAX COURT
JOHN R. RAY IV AND ROCHELLE L. RAY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
JENNIE S. RAY, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 5316-05S, 7558-05S. Filed July 17, 2006.
Juan F. Vasquez, Jr., for petitioners in docket No. 5316-
05S.
Peter A. Lowy, for petitioner in docket No. 7558-05S.
Gordon P. Sanz, for respondent.
DEAN, Special Trial Judge: These consolidated cases were
heard pursuant to the provisions of section 7463 of the Internal
Revenue Code in effect at the time the petitions were filed.
Unless otherwise indicated, subsequent section references are to
the Internal Revenue Code as in effect for the year at issue, and
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