POE v. SEABORN

No. 15.

282 U.S. 101 (1930)

POE, COLLECTOR OF INTERNAL REVENUE, v. SEABORN.

Supreme Court of United States.

Decided November 24, 1930.


Attorney(s) appearing for the Case

Solicitor General Thacher, with whom Assistant Attorney General Youngquist, Mr. Sewall Key and Miss Helen R. Carloss, Special Assistants to the Attorney General, Messrs. Clarence M. Charest, General Counsel, and T.H. Lewis, Jr., Special Attorney, Bureau of Internal Revenue, were on the brief, for Poe, Collector of Internal Revenue.

Mr. George Donworth, with whom Messrs. Elmer E. Todd, Frank E. Holman, and Charles T. Donworth were on the brief, for Seaborn.


MR. JUSTICE ROBERTS delivered the opinion of the Court.

Seaborn and his wife, citizens and residents of the State of Washington, made for the year 1927 separate income tax returns as permitted by the Revenue Act of 1926 c. 27, § 223 (U.S.C. App., Title 26, § 964).

During and prior to 1927 they accumulated property comprising real estate, stocks, bonds and other personal

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