Paula L. Wilson - Page 2















                            T.C. Summary Opinion 2007-117                             


                               UNITED STATES TAX COURT                                


                           PAULA L. WILSON, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      
                         MICHAEL EDWARD RYAN, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket Nos. 22721-05S, 22747-05S.    Filed July 11, 2007.              


               Scott P. Hendricks, for petitioners.                                   
               Catherine S. Tyson, for respondent.                                    


               FOLEY, Judge:  This case was heard pursuant to section 74631           
          of the Internal Revenue Code in effect when the petitions were              


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







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