United States Supreme Court
282 U.S. 101 (1930)
Mr. and Mrs. Seaborn (plaintiffs) resided in Washington, a community-property state, and filed separate federal income-tax returns. On their tax returns, the Seaborns each reported, as gross income, one-half of Mr. Seaborn’s salary and one-half of the proceeds from the sale of real estate held in Mr. Seaborn’s name. By dividing the income as opposed to filing jointly, the Seaborns were able to lower their tax bracket. The federal tax commissioner (commissioner) (defendant) issued a deficiency notice against Mr. Seaborn, determining that all of his salary should been reported as gross income on his own individual tax return, rather than divided with Mrs. Seaborn. The Seaborns filed suit against the commissioner in federal district court, seeking a tax refund. The district court entered judgment in favor of the Seaborns, holding that they were entitled to file separate tax returns with each claiming one-half of the community income. The commissioner appealed. The court of appeals certified the issue to the United States Supreme Court.
Rule of Law
Holding and Reasoning (Roberts, J.)
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