Citations 282 U.S. 101 (more) Date 1930 | Majority Roberts | |
Full case name Poe, Collector of Internal Revenue v. Seaborn | ||
Doing away with poe v seaborn a contrarian view
Poe v. Seaborn, 282 U.S. 101 (1930), was a United States Supreme Court case in which the Court held that a married person's income may be divided with his spouse in a community property state because by operation of state law, the income earned by one spouse is immediately the one half the property of the other spouse. Unlike the High Court's holding in Lucas v. Earl in which the opinion disallowed income splitting because it would have constituted an assignment of income over which the taxpayer had control, the one half of income earned by taxpayer was immediately income of his spouse and the taxpayer could not decide otherwise.
The assignment of income doctrine is similar to the doctrine of constructive receipt which holds that taxpayer's realize taxable income in the year in which taxpayer can control, i.e. take his income, but decides nevertheless to defer taking the case or in kind income in a later taxable year.
Because the United States Congress responded to the different treatment of married taxpayers in community property states and non community property states by creating the tax filing statuses "married filing jointly" and "married filing separately" today this is only of historical importance.