David R. Braden and Sharon F. Braden - Page 21




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          financial contribution to petitioners’ household is taken into              
          account.  See Klimenko v. Commissioner, supra.                              
               We conclude that it is inequitable to hold petitioner liable           
          for that part of the deficiency attributable to the distributions           
          received by Ms. Braden in 1995 and that, therefore, the                     
          requirement of section 6015(b)(1)(D) is satisfied.                          
               Conclusion                                                             
               After carefully reviewing the record in this case, we hold             
          that petitioner has satisfied each of the requirements of section           
          6015(b)(1) and that he is entitled to be relieved of liability              
          for tax attributable to the distributions received by Ms. Braden            
          in 1995.                                                                    
               To reflect the foregoing and the stipulation of settled                
          issues,                                                                     

                                                  Decision will be entered            
                                             under Rule 155.                          



















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