Legal Opinion

O'Neil v. Commissioner

United States Board of Tax Appeals

Decided May 21, 1929No. Docket No. 16864PublishedCited by 7 opinions

1. Farm rentals received in the year 1920 from real estate situated in the state of Texas which was the separate estate of a husband, constitute community income under the laws of Texas. 2. Oil royalties received in the year 1920 from real estate situated in the State of Oklahoma which was the separate estate of a husband living in Texas, constitute separate income of the husband.

1Opinion of the Court

OPINION.

Milliken :

These proceedings were submitted on the pleadings and on a stipulation to the effect that petitioners, John O’Neil and Frances O’Neil, were during the year involved husband and wife, who then resided in Texas. The deficiencies involved are for the calendar year 1920, the deficiency against petitioner John O’Neil is in the sum of $7,532.23 and the deficiency against petitioner Frances O’Neil is in the sum of $5,675.43. In his answer respondent alleges that the correct deficiencies are $4,543.77 against petitioner John O’Neil and $3,306.54 against petitioner Frances O’Neil.…

2Cases cited5 opinions

  1. Arnold v. LeonardTexas Supreme Court · 1925
  2. American Indemnity Co. v. City of AustinTexas Supreme Court · 1922
  3. Stephens v. StephensCourt of Appeals of Texas · 1927
  4. Dallas Joint Stock Land Bank of Dallas v. BrittonTexas Supreme Court · 1940
  5. Willcutt v. WillcuttCourt of Appeals of Texas · 1925

3Cited by7 opinions

  1. Sneed v. CommissionerUnited States Board of Tax Appeals · 1934
  2. Hammonds v. CommissionerUnited States Board of Tax Appeals · 1938
  3. Michna v. CommissionerUnited States Board of Tax Appeals · 1931
  4. O'Neil v. CommissionerUnited States Board of Tax Appeals · 1929
  5. Skaggs v. CommissionerUnited States Board of Tax Appeals · 1938

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