Samuels v. Commissioner

*412 This is a proceeding for the redetermination of a deficiency in income tax for the year 1921 in the amount of $1,526.19. It is alleged that the respondent erred in treating the entire community income as income of the petitioner.

FINDINGS OF FACT.

During the calendar year 1921 the petitioner was a married man, domiciled and living with his wife in the State of California. For the year 1921 the petitioner and his wife filed separate income-tax returns, in which each reported one-half of the community income. On an audit of the returns the respondent added the income reported by the wife to the income of the petitioner, resulting in a deficiency of $1,526.19.

OPINION.

ARUNDELL: The issue involved in this proceeding is governed by our decision in the .

Judgment will be entered for the respondent.