Braddock v. Comm'r

RICHARD G. BRADDOCK, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Braddock v. Comm'r

Docket No. 590-14S

United States Tax Court

T.C. Summary Opinion 2016-46; 2016 Tax Ct. Summary LEXIS 47;

August 24, 2016, Filed

Decision will be entered under Rule 155.

Peter G. McGrath, for petitioner.

Johnny Craig Young and Corey R. Clapper, for respondent.

LEYDEN, Special Trial Judge.

LEYDEN

SUMMARY OPINION

LEYDEN, Special Trial Judge: This case was heard pursuant to the provisions of section 7463 of the Internal Revenue Code in effect when the petition was filed.1 Pursuant to section 7463(b), the…