Lucas v. Earl

holding that husband’s entire salary was taxable notwithstanding agreement with wife to hold any acquired property as joint tenants | holding that the predecessor tax statute taxed salaries “to those who earned them” and that “the tax could not be escaped by anticipatory arrangements and contracts however skillfully devised.” | concluding that, based on an earlier version of the federal tax code, “[t]here is no doubt that ... salaries [are taxable] to those who earned them” | concluding that, based on an earlier version of the federal tax code, “[t]here is no doubt that the statute could tax salaries to those who earned them” | holding that income is taxable to the taxpayer who earns it, and the tax cannot “be escaped by anticipatory arrangements and contracts however skillfully devised to prevent the salary when paid from vesting even for a second in the man who earned it” | explaining that an argument that one is “not a ‘person’ and that the wages . . . [are] not ‘income’ is fatuous as well as obviously incorrect” | refusing to allow a taxpayer to escape taxes through “anticipatory arrangements and contracts however skillfully devised to prevent the [income] ... from vesting even for a second in the [one] who earned it” | refusing to permit taxpayer to evade taxes through “anticipatory arrangements and contracts however skillfully devised to prevent the [income] ... from vesting even for a second in the [taxpayer] who earned it.” | husband assigned to wife half of salary and fees that he earned; Federal taxing statute treats assigned amounts as taxpayer’s income | husband assigned to wife half of salary and fees that he earned; Federal taxing statute treats assigned amounts as taxpayer's income | husband’s salary is income to him and therefore taxable to him notwithstanding a contract with his wife under which all of their earnings were to be held by both as joint tenants | “There is no doubt that the statute could tax salaries to those who earned them * * *.” | contract between husband and wife whereby husband assigned half of all future income to wife held ineffective to avoid taxation on husband’s income | husband assigned to wife half of salary and fees that he earned; Federal taxing statute treats assigned amounts as taxpayer’s income | attorney contracted with his wife that all property acquired during their marriage would be taken in joint tenancy; despite validity of contract, attorney’s salary in whole taxable to him | “[N]o distinction can be taken according to the motives leading to the arrangement by which the fruits are attributed to a different tree from that on which they grew.” | "* * * no distinction can be taken according to the motives leading to the arrangement by which the fruits are attributed to a different tree from that on which they grew." | taxpayer assigned to wife one-half interest in his earnings | taxpayer assigned to wife one-half interest in his earnings | anticipatory assignments of income do hot reduce taxable income | taxpayer assigned to wife one-half interest in his earnings | income is taxed to the person who earned it | "There is no doubt that the statute could tax salaries to those who earned them and provide that the tax could not be escaped by anticipatory arrangements and contracts however skillfully devised to prevent the salaiy from vesting even for a second in the man who earned it.”