The Earls were married and by a contract made in 1901 Earl and his wife agreed to that any property that they had or may thereafter acquire in any way will be held as joint tenants and not with the right of survivorship. Earl claimed that because of this contract he could only be taxed on 1/2 of his income in 1920 and 1921. The IRS taxed the whole. The tax court agreed with the IRS, but the Court of Appeals reversed. The Supreme Court granted certiorari.

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