Lucas v. Earl
E296553
Lucas v. Earl is a landmark 1930 U.S. Supreme Court tax law case that established the principle that income is taxed to the person who earns it, regardless of contractual arrangements to split or assign that income.
All labels observed (2)
| Label | Occurrences |
|---|---|
| Lucas v. Earl canonical | 1 |
| Lucas, Commissioner of Internal Revenue v. Earl | 1 |
How this entity was disambiguated
This entity first appeared as the object of triple T2761784 — resolving that mention is where its identity was fixed. The disambiguator weighed these candidate entities and picked the highlighted one (or “None”, minting a new entity). This is how homonymy is resolved: the same surface form can point to different entities.
NED1
Entity disambiguation (via context triple)
gpt-5-mini-2025-08-07
Target entity: Lucas v. Earl Context triple: [Helvering v. Horst, relatedCase, Lucas v. Earl]
-
A.
Briggs v. Elliott
Briggs v. Elliott was a landmark federal court case from South Carolina challenging racial segregation in public schools, and it became one of the key cases consolidated into Brown v. Board of Education.
-
B.
Ray v. Blair
Ray v. Blair is a 1952 U.S. Supreme Court case that upheld a state's authority to require presidential electors to pledge support for their party's nominees as a condition of appointment.
-
C.
Romer v. Evans
Romer v. Evans is a 1996 U.S. Supreme Court case that struck down a Colorado constitutional amendment targeting gay, lesbian, and bisexual people as a violation of the Equal Protection Clause.
-
D.
McDonald v. Smith
McDonald v. Smith is a 1985 U.S. Supreme Court case that held the First Amendment’s Petition Clause does not grant absolute immunity from libel suits for statements made in petitions to government officials.
-
E.
Luther v. Borden
Luther v. Borden is an 1849 U.S. Supreme Court case that established the "political question" doctrine by holding that the determination of a state's legitimate government under the Constitution’s Guarantee Clause is a matter for Congress, not the courts.
- F. None of above. chosen
- G. Unsure - the case is ambiguous/there is not enough information to decide.
NED2
Entity disambiguation (via description)
gpt-5-mini-2025-08-07
Target entity: Lucas v. Earl Target entity description: Lucas v. Earl is a landmark 1930 U.S. Supreme Court tax law case that established the principle that income is taxed to the person who earns it, regardless of contractual arrangements to split or assign that income.
-
A.
Briggs v. Elliott
Briggs v. Elliott was a landmark federal court case from South Carolina challenging racial segregation in public schools, and it became one of the key cases consolidated into Brown v. Board of Education.
-
B.
Ray v. Blair
Ray v. Blair is a 1952 U.S. Supreme Court case that upheld a state's authority to require presidential electors to pledge support for their party's nominees as a condition of appointment.
-
C.
Romer v. Evans
Romer v. Evans is a 1996 U.S. Supreme Court case that struck down a Colorado constitutional amendment targeting gay, lesbian, and bisexual people as a violation of the Equal Protection Clause.
-
D.
McDonald v. Smith
McDonald v. Smith is a 1985 U.S. Supreme Court case that held the First Amendment’s Petition Clause does not grant absolute immunity from libel suits for statements made in petitions to government officials.
-
E.
Luther v. Borden
Luther v. Borden is an 1849 U.S. Supreme Court case that established the "political question" doctrine by holding that the determination of a state's legitimate government under the Constitution’s Guarantee Clause is a matter for Congress, not the courts.
- F. None of above. chosen
Statements (45)
| Predicate | Object |
|---|---|
| instanceOf |
United States Supreme Court case
ⓘ
landmark case ⓘ tax law case ⓘ |
| appliesTo |
earned income
ⓘ
salaries and professional fees ⓘ |
| areaOfLaw |
federal tax law
ⓘ
tax law ⓘ |
| category |
United States Supreme Court cases
ⓘ
United States Supreme Court cases of the White Court ⓘ
surface form:
United States Supreme Court cases of the Taft Court
United States taxation and revenue case law ⓘ |
| citation | 281 U.S. 111 ⓘ |
| coreRule | Tax liability follows control over earning the income ⓘ |
| country |
United States of America
ⓘ
surface form:
United States
|
| court | Supreme Court of the United States ⓘ |
| courtTerm | 1929 term ⓘ |
| decisionDate | 1930-05-19 ⓘ |
| factPattern |
Taxpayer attempted to avoid tax by assigning half of his salary and fees to his wife
ⓘ
Taxpayer had a contract with his spouse to share all income equally ⓘ |
| frequentlyCitedIn |
United States taxation and revenue case law
ⓘ
surface form:
U.S. Tax Court decisions
federal appellate tax cases ⓘ |
| fullCaseName |
Lucas v. Earl
self-linksurface differs
ⓘ
surface form:
Lucas, Commissioner of Internal Revenue v. Earl
|
| holding | Income is taxed to the person who earns it, regardless of contractual arrangements to split or assign that income ⓘ |
| influenced |
Commissioner v. Culbertson
ⓘ
Helvering v. Horst ⓘ United States v. Basye ⓘ |
| issue | Whether a contractual agreement to split income between spouses can shift tax liability ⓘ |
| jurisdiction |
United States of America
ⓘ
surface form:
United States
|
| keyDoctrine |
anticipatory assignment of income is ineffective for tax purposes
ⓘ
income is taxed to the earner ⓘ |
| languageOfWork | English ⓘ |
| legalSubject |
assignment of income doctrine
ⓘ
federal income tax ⓘ taxation of income ⓘ |
| majorityOpinionBy | Oliver Wendell Holmes Jr. ⓘ |
| opinionType | majority opinion ⓘ |
| page | 111 ⓘ |
| petitioner | Lucas, Commissioner of Internal Revenue ⓘ |
| precedentStatus | binding precedent in U.S. federal tax law ⓘ |
| principleEstablished | assignment of income doctrine ⓘ |
| respondent | Earl ⓘ |
| result | The income was taxable entirely to the husband who earned it ⓘ |
| unanimousDecision | true ⓘ |
| usedFor | interpretation of Internal Revenue Code provisions on income attribution ⓘ |
| volume | 281 U.S. ⓘ |
| yearDecided | 1930 ⓘ |
How these facts were elicited
The pipeline generated the facts above by prompting gpt-5.1 with this entity's name + description and the instruction below.
Instruction
You are a knowledge base construction expert. Given a subject entity and a description of it, return factual statements that you know for the subject as a JSON list of dictionaries(triples), where keys must be "subject", "predicate" and "object". The number of facts may be very high, between 25 to 50 or more, for very popular subjects. For less popular subjects, the number of facts can be very low, like 5 or 10. # Requirements - If you don't know the subject at all, return an empty list. - If the subject is not a named entity, return an empty list. - Include at least one triple where predicate is "instanceOf". - Do not get too wordy. - Separate several objects into multiple triples with one object.
Input
Subject: Lucas v. Earl Description of subject: Lucas v. Earl is a landmark 1930 U.S. Supreme Court tax law case that established the principle that income is taxed to the person who earns it, regardless of contractual arrangements to split or assign that income.
Referenced by (2)
Full triples — surface form annotated when it differs from this entity's canonical label.
this entity surface form:
Lucas, Commissioner of Internal Revenue v. Earl