Syllabus

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 5 Cir., 430 F.2d 1 and 7 reversed.

William Terry Bray, Austin, Tex., for petitioners.

Paul K. Kirkpatrick, Jr., Washington, D.C., for respondent Anne Goyne Mitchell.

Patrick M. Schott, New Orleans, La., for respondent Frances Angello.

Mr. Justice BLACKMUN delivered the opinion of the Court.