OPINION.
HARRON, Judge:
The petitioners, husband and wife, filed separate, individual income tax returns for 1945. All of their income for 1945 is community income, and each spouse reported his one-half thereof in his separate, individual return. The respondent has determined a deficiency for each petitioner, part of which is in dispute. The question to be decided arises under section 107 (a) of the Code
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