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I was recently going through an old book I had teaching how to write HTML and creating a Web site explaining all the problems with its code (horribly invalid is the nicest way I can say it), and discovered a bug with paragraph nesting. I had uploaded the file from my hard disk and set up a few overrides: DOCTYPE - HTML 2.0 ENCODING - UTF-8 (the original had no valid DOCTYPE declaration) and oddly enough it accepted the following code: <P>I made it...</P> <BR>to tell everyone about me I believe this is a nesting error (the paragraph tag is specifically closed, yet the line break is allowed outside of it), but am not entirely sure. At any rate, I tried it with HTML 3.2, then 4.01 Transitional, then XHTML 1.0 Transitional, and only the last one failed to validate (and that was only because the document was in all uppercase, which I understand is not allowed in XHTML).
Chances are that this is perfectly legal in those document types as it depends on the content model of the parent element of the br element whether it is allowed at that position, for example, in HTML 4.01 Transitional you can use <body> ... <br> ... </body> while you can't do that in HTML 4.01 Strict.
Without a sample document / URI, and given that nesting validation is fairly well tested, I agree with Comment #1, and think the particular markup given in comment #0 probably was valid in its context.