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Poe v. Seaborn | 282 U.S. 101 (1930)

How can federal income-tax rules apply differently to married couples living in different states? The United States Supreme Court explained how in Poe versus Seaborn.

H. G. and Charlotte Seaborn resided in Washington State, a community-property state. Their primary source of income was H. G.’s salary, bank account interest, and investment dividends. In nineteen twenty-seven, the couple acquired stocks, bonds, and other property. They bought real estate in H. G.’s name, but the property was undisputedly community property. Neither owned separate property nor had any separate income.

The Seaborns filed separate income-tax returns in which each reported half the community income as gross income and deducted half the community expenses. Collector of Internal Revenue Burns Poe determined that all of H. G.’s salary should’ve been reported on his return, which would’ve moved him into a higher tax bracket. Poe imposed an additional assessment against H. G., which the Seaborns paid under protest. When their protest was denied, the Seaborns sued Poe in federal court.

The district court ruled for the Seaborns, and Poe appealed. The Ninth Circuit certified the question to the United States Supreme Court.

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