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Lucas v. Earl, 281 U.S. 111 (1930), is a United States Supreme Court case concerning U.S. Federal income taxation, about a man who reported only half of his earnings for years 1920 and 1921. Guy C. Earl and his wife had entered into a contract that would potentially save a lot of tax. The contract specified that earnings were owned by the couple as joint tenants. It is unlikely that it was tax-motivated, since there was no income tax in 1901 when they executed the contract. Justice Oliver Wendell Holmes, Jr. delivered the Court’s opinion which generally stands for the proposition that income from services is taxed to the party who performed the services. The case is used to support the proposition that the substance of the transaction, rather than the form, is controlling for tax purposes.

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  • Lucas v. Earl (en)
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  • Lucas v. Earl, 281 U.S. 111 (1930), is a United States Supreme Court case concerning U.S. Federal income taxation, about a man who reported only half of his earnings for years 1920 and 1921. Guy C. Earl and his wife had entered into a contract that would potentially save a lot of tax. The contract specified that earnings were owned by the couple as joint tenants. It is unlikely that it was tax-motivated, since there was no income tax in 1901 when they executed the contract. Justice Oliver Wendell Holmes, Jr. delivered the Court’s opinion which generally stands for the proposition that income from services is taxed to the party who performed the services. The case is used to support the proposition that the substance of the transaction, rather than the form, is controlling for tax purposes. (en)
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  • (en)
  • Earl (en)
  • v. (en)
  • Robert H. Lucas, Commissioner of Internal Revenue (en)
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  • unanimous (en)
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  • Lucas v. Earl, (en)
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  • Earl (en)
  • v. (en)
  • Robert H. Lucas, Commissioner of Internal Revenue (en)
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  • All of a husband's earnings are to be taxed to husband even though husband and wife had previously entered into an agreement under which all earnings of husband and wife “shall be treated and considered and hereby is declared to be received, held, taken, and owned by us as joint tenants, and not otherwise, with the right of survivorship.” (en)
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  • Lucas v. Earl (en)
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  • Holmes (en)
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  • Lucas v. Earl, 281 U.S. 111 (1930), is a United States Supreme Court case concerning U.S. Federal income taxation, about a man who reported only half of his earnings for years 1920 and 1921. Guy C. Earl and his wife had entered into a contract that would potentially save a lot of tax. The contract specified that earnings were owned by the couple as joint tenants. It is unlikely that it was tax-motivated, since there was no income tax in 1901 when they executed the contract. Justice Oliver Wendell Holmes, Jr. delivered the Court’s opinion which generally stands for the proposition that income from services is taxed to the party who performed the services. The case is used to support the proposition that the substance of the transaction, rather than the form, is controlling for tax purposes. (en)
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  • Hughes (en)
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