Nature of the Case
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Facts
Seaborn (D) his wife were residents of Washington and did separate returns for their 1927 taxes. In 1927 they accumulated property in real estate, stocks, bonds, and other personal property. The real estate stood in D’s name alone, but the rest of the property constituted community property and neither owned any separate property or had any separate income. Income was composed of D’s salary and interest in bank deposits, bonds, dividends and profits on sales of real and personal property. D and his wife each returned ½ of the community income as gross income and each deducted ½ of the community expenses to create the net income on their respective returns. The IRS determined that all of the income should have been reported on D’s return.
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