Davidson v. Commissioner of Internal Revenue

FOSTER, Circuit Judge.

Adam H. Davidson and his wife, Clifford Drake Davidson, domiciled in Dallas, Tex., filed separate returns for income taxes for the calendar year 1927, dividing the community income, under the Texas law, between them. The Commissioner determined a deficiency of $19,859.53 as to each taxpayer. On petition to the Board of Tax Appeals the Commissioner’s ruling was affirmed. 34 B.T.A. 479. The case is before us on petition of the wife, with a stipulation that a similar judgment may be entered on the petition of the husband. We refer to the opinion of the Board for the facts…