Owens v. Commissioner

OPINION.

TURNER, Judge:

Our first question is whether the income of petitioner and Leo, particularly the fees received by Leo for his services in managing the three Texas newspapers, was properly reported on a community basis. It is fairly well settled, we think, that the ownership of income received from personal services is determined by the laws of the domicile of the earner of such income at the time the income is earned. Herbert Marshall, 41 B. T. A. 1064; Nathamel Shilkret, 46 B. T. A. 1163, affd. 138 F. 2d 925; Benjamin H. McElhinney, Jr., 17 T. C. 7; and Marjorie Hunt, 22 T. C. 228. And…