San Diego Law Review

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It is the design of this comment to delve into the history, scope and purpose of section 911 of the Internal Revenue Code and,in particular, of subsection 911(c)(3). This inquiry will be made in conjunction with a critical analysis of the Tax Court's decision in Robert R. Bottome, a decision which results in unequal treatment of taxpayers in domiciled in community property states and non-community property states.

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