MacMurray v. Commissioner
United States Tax Court
1. Husband and wife owned a ranch business as community property. The total deductions (other than taxes and interest) attributable to the business as a whole exceeded by more than $ 50,000 the gross income derived therefrom for each of 5 successive years, but the share of those deductions available to each spouse did not exceed such spouse's share of the gross income from such business by more than $ 50,000 for 5 successive years.
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1. Husband and wife owned a ranch business as community property. The total deductions (other than taxes and interest) attributable to the business as a whole exceeded by more than $ 50,000 the gross income derived therefrom for each of 5 successive years, but the share of those deductions available to each spouse did not exceed such spouse's share of the gross income from such business by more than $ 50,000 for 5 successive years. Held, section 130, Internal Revenue Code, is inapplicable. 2. Petitioners MacMurray, Fenton, and a third person purchased a story in 1944 and sold it in 1945 to…
1DissentOpper, J.
In the face of complicated and intricate measures designed by Congress to equalize the tax burden of married couples- in community and noncommunity property states, see H. Eept. No. 1274, 80th Cong., 2d Sess., p. 1; S. Eept. No. 1013, 80th Cong., 2d Sess., p. 1, we are arriving at a result which gives to community property taxpayers the benefit of a deduction unavailable to those residing in other sections of the country. As so often in the past, we are once more permitting formalistic terms of ancient property law to override the exigencies of a modern and uniform national tax system. E. g.,…
2Cases cited8 opinions
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- Helvering v. CliffordSupreme Court of the United States · 1940
- Lucas v. EarlSupreme Court of the United States · 1930
- Diamond A Cattle Co. v. CommissionerUnited States Tax Court · 1953
- Commissioner of Internal Revenue v. GrayCourt of Appeals for the Fifth Circuit · 1947
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