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6 B.T.A. 1084

Samuels v. Commissioner

United States Board of Tax Appeals

Decided April 29, 1927

United States Board of Tax Appeals · decided 1927-04-29

The Commissioner correctly held that the petitioner and his wife were not entitled to file separate returns, reporting each one-half of the income received during the year on the community property basis.

Relies on United States v. Robbins · Cerruti v. Commissioner

Decided 1927-04-29

¶1OPINION.

Littleton:

¶2Upon the authority of United States v. Robbins, 269 U. S. 315, and the Board’s opinion in the Appeal of D. Cerruti, 4 B. T. A. 682, it is held that the Commissioner correctly increased petitioner’s income as reported by him by the amount of the income received by him during the year 1921 and reported by his wife.

¶3Judgment will be entered for the respondent.

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