Federal Income TaxAssignment of income
Lucas v. Earl
Supreme Court of the United States · Decided March 17, 1930 · Core case
Full citation
Lucas v. Earl, 281 U.S. 111 (1930).
VerifiedQuotes, pinpoints and citation checked word for word against the opinion; facts checked against the opinion before publication. October 23, 2026.This brief explains the opinion as issued. Later treatment and current-law status are not assessed here.
Lucas, Commissioner of Internal Revenue
tax commissioner
Earl
attorneyrespondent
Brief
Facts
Earl earned a salary and attorney's fees in 1920 and 1921. By a contract made in 1901, he and his wife agreed that any property either of them then had or might later acquire in any way, including earnings such as salaries and fees, and any property received by gift, bequest, devise or inheritance, together with all proceeds, issues and profits of it, would be held and owned by them as joint tenants with the right of survivorship. The argument for taxing only half was that the salary and fees became joint property at the instant they were received. The Court expressed hesitation about that proposition. The parties lived in California, and the contract's validity was not questioned; the Court assumed it unquestionable under California law. The Commissioner of Internal Revenue and the Board of Tax Appeals taxed Earl on the whole of that income. The question was whether he should be taxed for only a half of it in view of the contract.
Issue
Under the revenue acts, should Earl be taxed for the whole of the salary and attorney's fees he earned in 1920 and 1921, or for only a half of them in view of his contract with his wife?
Holding
Earl could be taxed for the whole of the salary and attorney's fees he earned, because the statute taxes salaries to those who earn them and is not escaped by anticipatory arrangements and contracts that keep the pay from vesting even for a second in the man who earned it.
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IRAC
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CREAC
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Cold calls
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