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 salary when paid from vesting even for a second in the man who earned it

Tax law makes "no distinction... according to the motives leading to the arrangement by which the fruits are attributed to a different tree from that on which they grew."

—it was held that the earnings of a husband were all taxable to him although he and his wife, residents of California, had entered into a valid contract that the earnings of either spouse should be received and owned by them as joint tenants.

The principle that income is taxed to the one who earns it is basic to our system of income taxation.

Here, there is no attempt at all to attribute fruit "to a different tree from that on which [it] grew."

Under the anticipatory assignment of income doctrine, "gains should be taxed to `those who earned them,'a maxim [the Supreme Court has] called `the first principle of income taxation.'"

Under the assignment of income doctrine, gross income from personal services must be included in the income of the person who earned it.

Petitioner's case is even more vulnerable than some by reason of the peculiar personal factor in the earning of the income in question.

We conclude from the entire record that for the period of time in issue the properties were owned by J & S; that the income therefrom was produced by its activities and that these attempted assignments of that income are invalid.