Branum v. Commissioner

WISDOM, Circuit Judge:

Appellant Mansel Branum believes that the decision in this case reflects our failure to administer a fair, simple and efficient tax system. Where he seeks an understanding and flexible Tax Code, ours offers him no solace. As we shall explain, his position deserves some sympathy. The applicable tax law, however, is unbending. Specifically, Branum seeks relief from the Tax Court’s holding that he made an effective election under section 172(b)(3)(C) of the Internal Revenue Code for his 1985 tax year when evidence indicated that his intention was otherwise. That holding is…