Mitchell v. Commissioner
United States Tax Court
1. Held, that under the community property laws of Louisiana a wife has a present, vested interest in the income of the community and is therefore under a duty to make either a single or a joint return, and is liable for the tax on one-half of community income; and this is so, even though the wife subsequently renounces the community of acquets and gains and takes nothing therefrom.
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1. Held, that under the community property laws of Louisiana a wife has a present, vested interest in the income of the community and is therefore under a duty to make either a single or a joint return, and is liable for the tax on one-half of community income; and this is so, even though the wife subsequently renounces the community of acquets and gains and takes nothing therefrom. Held, further, that wife's failure to file a return was without reasonable cause and her failure to pay the tax was negligent. Determined penalty for underpayment of estimated tax is mandatory since statutory…
1Opinion of the Court
Anne Goyne Mitchell, Petitioner v. Commissioner of Internal Revenue, Respondent; Jane Isabell Goyne Sims, Petitioner v. Commissioner of Internal Revenue, Respondent
Mitchell v. Commissioner
Docket Nos. 6740-66, 6741-66
United States Tax Court
51 T.C. 641; 1969 U.S. Tax Ct. LEXIS 204;
January 27, 1969, Filed
Decisions will be entered under Rule 50.
1. Held, that under the community property laws of Louisiana a wife has a present, vested interest in the income of the community and is therefore under a duty to make either a single or a joint return, and is liable for the tax on one-half of community…
2Cases cited25 opinions
- Commissioner v. Estate of BoschSupreme Court of the United States · 1967
- Poe v. SeabornSupreme Court of the United States · 1930
- Hopkins v. BaconSupreme Court of the United States · 1930
- United States v. MalcolmSupreme Court of the United States · 1931
- Ruben v. CommissionerUnited States Tax Court · 1960
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