Millard D. and Marjorie C. Thomas - Page 2















                            T.C. Summary Opinion 2007-110                             


                               UNITED STATES TAX COURT                                


                  MILLARD D. AND MARJORIE C. THOMAS, Petitioners v.                   
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 22366-04S, 11333-05S.    Filed June 28, 2007.              


               Millard D. and Marjorie C. Thomas, pro se.                             
               Daniel N. Price, for respondent.                                       


               WHERRY, Judge:  These consolidated cases arise from                    
          petitions for judicial review of notices of deficiency.  They               
          were heard pursuant to the provisions of section 7463 of the                
          Internal Revenue Code in effect when the petitions were filed.1             


               1Unless otherwise indicated, section references are to the             
          Internal Revenue Code in effect for the years in issue, and all             
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  





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