¶2The sole issue in this appeal falls squarely within our decision in Guy C. Earl, 10 B. T. A. 723, holding that the earnings of the husband are taxable to him when received even though he has, by an assignment which is legal and enforceable under the laws of the State of California, released to his wife as her separate property one-half of his earnings. We therefore sustain the respondent.
¶3Judgment will be entered for the respondent.