Drumheller v. Commissioner

*211OPINION.

Trammell:

The portion of the deficiency for the calendar year 1925 which is in issue results from the inclusion in petitioner’s gross income of the whole amount of a dividend on Whitehouse-Drumheller Company stock (owned by the marital community) distributable by the company in that year. The deficiency for the calendar year 1927 results from the inclusion in petitioner’s gross income for that year of $33,886.24, representing one-half the income of the community estate of which Anna M. Drumheller, deceased wife of petitioner, and petitioner had been owners.

The basis of respondent’s…