In In re Nominating Petition of Brady, 923 A.2d 1206 (Pa. Cmwlth. 2007), the Court considered a case where a candidate held an unpaid administrative assistant position with his union. The candidate received no wages, but the union made payments to maintain his membership in the union pension fund, which he did not report on Box 10. The Court noted that the instructions for Box 10 at that time were materially different from the definition of income in Section 1102 of the Ethics Code as they did not include the phrase "thing of value received...." Although the Court concluded that the candidate received a "thing of value," it held that he was entitled to rely upon the instructions and that this was not a fatal defect. It observed: "We also note that our Supreme Court has instructed us that due to 'the harsh consequence that would accompany a construction that would lead to a finding of a material non-disclosure, ...' any ambiguity in the definition should be construed most favorably to candidates seeking ballot access." Id. at 1210 n 6.