United States v. Mitchell (403 U.S. 190)

United States Supreme Court

403 U.S. 190

United States et al.  v.  Mitchell et al.

Certiorari to the United States Court of Appeals

No. 798  Argued: April 20, 1971 --- Decided: June 7, 1971

A married woman domiciled in Louisiana, where under state law the wife has a present vested interest in community property equal to that of her husband, is personally liable for federal income taxes on her one-half interest in community income realized during the existence of the community, notwithstanding her subsequent renunciation under state law of her community rights, since federal, not state, law governs what is exempt from federal taxation. Pp. 194-206.

430 F. 2d 1 and 7, reversed.

BLACKMUN, J., delivered the opinion for a unanimous Court.

William Terry Bray argued the cause for the United States et al. With him on the brief were Solicitor General Griswold, Assistant Attorney General Walters, Matthew J. Zinn, and Crombie J.D. Garrett.

Paul K. Kirkpatrick, Jr., argued the cause and filed a brief for respondent Mitchell. Patrick M. Schott argued the cause and filed a brief for respondent Angello.

Notes