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Lucas v. Earl
''Lucas v. Earl'', 281 U.S. 111 (1930),〔See (281 U.S. 111 at Findlaw ).〕 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. 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.〔281 U.S. 111, 115.〕 The case is used to support the proposition that the substance of the transaction, rather than the form, is controlling for tax purposes.〔See ().〕
==Facts and procedural history==
Guy C. Earl was an attorney who entered into a contract with his wife whereby all property and earnings were to be "treated and considered . . . to be . . . owned by us (and his wife ) as joint tenants . . . with rights of survivorship."〔281 U.S. 111, 113–14.〕 Earl intended to cut his tax liability in half.〔Id. at 113.〕 The issue before the court centered on whether Guy Earl alone or, alternatively, Earl and his wife, should be taxed on the salary and attorneys fees earned by Earl in 1920 and 1921.〔Id.〕
The Bureau of Internal Revenue (the predecessor to the Internal Revenue Service) determined, and the Board of Tax Appeals (predecessor to the United States Tax Court) ruled, that the tax imposed on Mr. Earl was imposed on his entire salary, including the portion assigned to his wife.〔Id. at 111.〕 Earl appealed, and the decision was reversed by the Circuit Court of Appeals for the Ninth Circuit.〔Id.〕
抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』
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