Legal Opinion

Beall v. Commissioner

United States Tax Court

Decided January 9, 1984No. Docket Nos. 14793-82, 10835-83PublishedCited by 4 opinions

Petitioner and her husband were residents of Arizona, a community property State, during the years in issue. Petitioner endorsed a "vow of poverty," executed by her husband, in which he purported to convey his income to a church.

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Petitioner and her husband were residents of Arizona, a community property State, during the years in issue. Petitioner endorsed a "vow of poverty," executed by her husband, in which he purported to convey his income to a church. Held, petitioner did not thereby relinquish her community property interest in her husband's earnings, and she is liable for deficiencies in tax attributable to her failure to report one-half of those earnings on separate returns filed by her and for additions to tax for negligence.

1Opinion of the Court

OPINION

Cohen, Judge•

Respondent determined deficiencies of $555 and $3,332 in petitioner’s Federal income taxes for the years 1978 and 1979, respectively, and additions to tax under section 6653(a)1 of $28 and $166.60 for those years, respectively. Petitioner contends that she has no liability for those taxes attributable to one-half of wages earned by her husband during the years in issue because she executed a vow of poverty in which her husband purported to convey his earnings to a chapter of the Life Science Church. Petitioner also contends that, because she in good faith filed separate…

2Cases cited11 opinions

  1. United States v. MitchellSupreme Court of the United States · 1971
  2. United States v. BasyeSupreme Court of the United States · 1973
  3. William H. And Avilda L. Edwards v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
  4. Stephenson v. CommissionerUnited States Tax Court · 1982
  5. McGahen v. CommissionerUnited States Tax Court · 1981

6 more not listed; retrieve them via the Exa API.

3Cited by4 opinions

  1. Beall v. CommissionerUnited States Tax Court · 1984
  2. Horner v. CommissionerUnited States Tax Court · 1994
  3. Layman v. CommissionerUnited States Tax Court · 1999
  4. Sanders v. CommissionerUnited States Tax Court · 1986

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