T.C. Summary Opinion 2006-78
UNITED STATES TAX COURT
CHARLES LEONARD BRADEN AND
JOICE STIEBER BRADEN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6736-05S. Filed May 11, 2006.
Charles Leonard Braden and Joice Steiber Braden,
pro se.
Stephen P. Baker, for respondent.
WHALEN, Judge: This case was filed pursuant to
section 7463 of the Internal Revenue Code as in effect
when the petition was filed. Unless otherwise indicated,
subsequent section references are to the Internal Revenue
Code in effect for the year in issue. The decision to be
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