BRANUM v. C.I.R.

No. 93-4251.

17 F.3d 805 (1994)

Mansell W. BRANUM, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

April 5, 1994.


Attorney(s) appearing for the Case

William P. Bowers, David Allen Miller, Jenken & Gilchrist, Dallas, TX, for petitioner-appellant.

Abraham N.M. Shashy, Jr., Chief Counsel, IRS, Charles Bricken, Gary R. Allen, Chief, Appellate Section, Tax Div., Dept. of Justice, Richard Farber, Washington, DC, for respondent-appellee.

Before WISDOM, BARKSDALE, and EMILIO M. GARZA, Circuit Judges.


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...

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