BOURQUIN, District Judge.
By agreed statements of facts herein, it appears that March 30, 1918, William Pigott and Ada, his wife, filed a joint income tax return for 1917, and July 30, 1920, they filed separate amended or substituted returns, each for one-half of the income of the original aforesaid to conform to community property laws. Within five years after the original return, the Commissioner assessed some $84,000 additional taxes, and the taxpayers filed claims...
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