"[1] The United States Supreme Court created the assignment of income doctrine in the Lucas v. Earl decision.
"[3] The case is used to support the proposition that the substance of the transaction, rather than the form, is controlling for tax purposes.
[4] The doctrine was later expanded in the Helvering v. Horst decision to include income from property.
[5] The decision relied on the principle that the power to dispose of income and the enjoyment of property's economic benefits is the equivalent of ownership.
[5] This doctrine has important implications for taxpayers trying to shift their tax burden to another person.