Leola Johnson Bell and David Arthur Bell v. Commissioner of Internal Revenue

TUTTLE, Circuit Judge.

The question presented on this petition for review is as to the correctness-of the decision of the Tax Court that taxpayers, husband and wife, who filed separate returns under the community property system in Louisiana, failed to report partnership income to which the husband became entitled during the year 1947. Taxpayers were residents of Louisiana and jurisdiction is conferred on the court to entertain this petition for review by the provisions of Section 1141 (a) of the Internal Revenue Code, as amended by Section 36 of the Act of June 25, 1948, 26 U.S.C.A. §…