United States v. Pierotti

ORR, Circuit Judge.

In this opinion appellant will be referred to as the Government and appellee as taxpayer.

The question involved is whether the property owned by taxpayer and her husband at the time of his death was held by them in joint tenancy or as so-called new ■style “post-1927” community property under •California law.

In assessing the tax the Government included all the property held by the parties at the time of the husband’s death. Taxpayer contended that only one-half should 'have been included. If the property was owned in joint tenancy the Government was .correct in its position.…