 | United States. Supreme Court - 1940 - 894 Seiten
...Taxes cannot be escaped "by anticipatory arrangements and contracts however skilfully devised . .-.. by which the fruits are attributed to a different tree from that on which they grew." Lucas v. Earl, 281 US Ill, 115. What Lay gave, Griffiths in reality got, and on that he must be taxed.... | |
 | United States. Board of Tax Appeals - 1931 - 1490 Seiten
...statute before us and we think that 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. Under the Earl case, we hold that the salary in question was correctly returned by the wife who earned... | |
 | United States. Congress. House. Committee on Ways and Means - 1942 - 1228 Seiten
...statute before us and we think that no distinction can be taken according ot the motives leading to the arrangement by which the fruits are attributed to a different tree from that on which they grew. Here the Court squarely based its decision on the control which was necessarily retained by the taxpayer,... | |
 | United States. Congress. House. Committee on Ways and Means - 1963 - 764 Seiten
...the word. The Horst decision was a development of the holding in Lucas v. Earl (1930), 281 US Ill, in which a husband was held taxable on all his income...rationale in many later income tax cases. The Horst decision was followed in the companion case of Hclvering v. Eubank (1940) 311 US 122, holding a life... | |
 | United States. Tax Court - 1968 - 732 Seiten
...Taxes cannot be escaped "by anticipatory arrangements and contracts however skillfully devised * * * by which the fruits are attributed to a different tree from that on which they grew." Lucas v. Earl. 281 US Ill, 115. * * * This is not to say however that had petitioner herein actually... | |
 | United States. Tax Court - 1985 - 1410 Seiten
...statute before us and we think that 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. [281 US at 114-115.] During the last half century since Lucas v. Earl, we have been advised repeatedly... | |
 | United States. Tax Court - 1974 - 936 Seiten
...statute before us and we think that 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. In resolving the question of which tree, in fact, bore the fruit, we must ascertain not who has apparent... | |
 | United States. Tax Court - 1984 - 1120 Seiten
...'fruit' of the tree, or as the US Supreme Court held, " * * * that no distinction can be taken * * * by which the fruits are attributed to a different tree from that on which they grew." Thus, the "Purchaser" is the legal owner of all the "Supplier's" future accounts receivable capital... | |
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... by anticipatory arrangements and contracts however skilfully devised to prevent the salary when paid from vesting even for a second in the man who earned it. That seems to us the import of the statute before us and we think that no distinction can... 
