Hill v. Commissioner
United States Tax Court
Petitioner and her former husband, residents of Texas, separated in 1947. At that time they considered the separation to be permanent, and ceased thereafter to live with each other. However, they made no agreement during the separation to dissolve the community, or to divide the community property acquired or to be acquired.
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Petitioner and her former husband, residents of Texas, separated in 1947. At that time they considered the separation to be permanent, and ceased thereafter to live with each other. However, they made no agreement during the separation to dissolve the community, or to divide the community property acquired or to be acquired. They were divorced in 1957. Held, respondent properly determined that petitioner was taxable on one-half the total income received during 1951 by her and her former husband.
1Opinion of the Court
Tietjens, Judge:
This proceeding involves a deficiency in income tax in the amount of $1,235.08 for the calendar year 1951.
The issue for decision is whether petitioner was a member of a Texas marital community during 1951 so that she was taxable on one-half the total income received during that year by her and her husband, from whom she was separated in 1947.
FINDINGS OF FACT.
The stipulated facts are so found, and are incorporated herein by this reference.
Christine K. Hill (hereinafter referred to as the petitioner) resided in Dallas, Texas, during 1951. She filed a separate individual Federal…
2Cases cited13 opinions
- SoRelle v. CommissionerUnited States Tax Court · 1954
- Brokaw v. CollettTexas Commission of Appeals · 1928
- Frame v. FrameTexas Supreme Court · 1931
- Sullivan v. CommissionerUnited States Tax Court · 1956
- Dorothy Sullivan v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
8 more not listed; retrieve them via the Exa API.
3Cited by19 opinions
- United States v. MitchellSupreme Court of the United States · 1971
- Bagur v. Comm'rUnited States Tax Court · 1976
- Johnson v. CommissionerUnited States Tax Court · 1979
- Carmen Ramos v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1970
- Connor v. CommissionerUnited States Tax Court · 1982
14 more not listed; retrieve them via the Exa API.