Lucas v. Earl

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Lucas v. Earl
by Oliver Wendell Holmes, Jr.
Syllabus

Lucas v. Earl, 281 U.S. 111 (1930), is a United States Supreme Court case concerning taxation, about a man who reported only half of his earnings for years 1920 and 1921. The case addresses the taxpayer's attempt at tax avoidance based on a contract with his wife. The contract specified that earnings were owned by the couple as joint tenants. 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.

879677Lucas v. Earl — SyllabusOliver Wendell Holmes, Jr.

United States Supreme Court

281 U.S. 111

Lucas  v.  Earl

 Argued: March 3, 1930. --- Decided: March 17, 1930

The Attorney General and Mr. Charles E. Hughes, Jr., Sol. Gen., of Washington, D. C., for petitioner.

Warren Olney, Jr., of San Francisco, Cal., for respondent.

[Argument of Counsel from pages 111-113 intentionally omitted]

Mr. Justice HOLMES delivered the opinion of the Court.

Notes

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This work is in the public domain in the United States because it is a work of the United States federal government (see 17 U.S.C. 105).

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