MARKS v. COMMISSIONER

Docket No. 6383.

8 T.C. 1255 (1947)

MELANIE DENNERY MARKS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 26, 1947.


Attorney(s) appearing for the Case

Gibbons Burke, Esq., for the petitioner.

D. Louis Bergeron, Esq., for the respondent.


This proceeding involves a deficiency in individual income taxes for the years 1939, 1940, and 1941, in the respective amounts of $2,374.24, $3,893.02, and $4,715.94.

The only issue involved is whether petitioner's husband, during the years 1939, 1940, and 1941, had the "administration" of her separate property to such an extent as to entitle him to report one-half of the income therefrom as his community one-half.

A stipulation of facts was filed. We adopt...

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