# Samuels v. Commissioner > United States Board of Tax Appeals · April 3, 1928 · 11 B.T.A. 412 URL: https://www.frixlaw.com/law-library/cases/4601765 ## Case - **Full name:** OSCAR SAMUELS, v. COMMISSIONER OF INTERNAL REVENUE - **Court:** United States Board of Tax Appeals - **Decided:** April 3, 1928 - **Citations:** 11 B.T.A. 412; 1928 BTA LEXIS 3820 - **Precedential status:** Published - **Opinion:** Opinion - **Judges:** Arundell - **Cited by:** 0 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4601765 ## Opinion text OSCAR SAMUELS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. Samuels v. Commissioner Docket No. 13534. United States Board of Tax Appeals 11 B.T.A. 412 ; 1928 BTA LEXIS 3820 ; April 3, 1928 , Promulgated *3820 W. W. Spalding, Esq., for the petitioner. J. F. Greaney, Esq., for the respondent. ARUNDELL *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. --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4601765. Public record. Not legal advice.