Anne Goyne Mitchell v. Commissioner of Internal Revenue, Jane Isabell Goyne Sims v. Commissioner of Internal Revenue

DYER, Circuit Judge:

These appeals from the Tax Court involve the question of a wife’s liability out of her separate property for federal income taxes on community income earned when she and her husband were residents and domiciliaries of Louisiana, a community property state. The Tax Court held that the wife is liable for the tax on one-half of all the community income regardless of whose efforts produced the income for the community and even though the wife did not file a return, renounced the community and received none of the community property upon the dissolution of the community. The…